Cases6008996/2024

Claimant v Pladis (UK) Limited

20 May 2025Before Employment Judge L BrownReadingremote video

Outcome

Other

Individual claims

Indirect Discrimination(race)not determined

Respondent applied to strike out the indirect race discrimination claim on the basis it had no reasonable prospect of success due to being presented outside the three-month primary time limit. The tribunal refused the strike-out application, finding the claimant had better than no reasonable prospect of persuading a tribunal at final hearing to extend time on just and equitable grounds. The claim relates to the respondent's alleged provision, criterion or practice of not accepting Polish sick certificates in 2022, which allegedly placed the claimant at a disadvantage. The substantive claim remains to be determined.

Facts

The claimant, a Polish national, provided Polish sick certificates to her employer in 2022 and was not paid sick pay because the respondent allegedly applied a provision, criterion or practice of not accepting Polish sick certificates. The claimant was eventually paid retrospectively in September 2022 after providing a UK sick note. Her employment ended in May 2024. She commenced ACAS early conciliation in June 2024 and filed her claim in August 2024, alleging indirect race discrimination. The respondent applied to strike out the claim as being substantially out of time.

Decision

Employment Judge T Brown refused the respondent's application to strike out the claim. The judge found that the claimant had more than a fanciful prospect of persuading an employment tribunal at a final hearing to extend time on just and equitable grounds. The judge noted the claimant's ill health, her concerns about bringing a claim while employed, the lack of evident forensic prejudice to the respondent, and the wide discretion afforded to tribunals on the just and equitable test.

Practical note

A strike-out application for time-bar issues in discrimination claims faces a high threshold where the tribunal has wide discretion under the just and equitable test, particularly where there is no clear forensic prejudice to the respondent.

Legal authorities cited

Tayside Public Transport Company Limited v Reilly [2012] IRLR 755EzsiasTwist DX v Armes [2020]

Statutes

Equality Act 2010

Case details

Case number
6008996/2024
Decision date
20 May 2025
Hearing type
preliminary
Hearing days
0.375
Classification
contested

Respondent

Sector
manufacturing
Represented
Yes
Rep type
solicitor

Claimant representation

Represented
Yes
Rep type
lay rep