Cases2403387/2024

Claimant v Secretary of State for Work and Pensions

16 May 2025Before Employment Judge JohnsonLiverpoolin person

Outcome

Partly successful

Individual claims

Discrimination Arising from Disability (s.15)(disability)partly succeeded

The tribunal found the claimant was not disabled due to Autism at the relevant times. The impairments identified (sleep difficulties, social difficulties, sensory issues) were attributable to the already-accepted conditions of fibromyalgia, PTSD, stress and anxiety rather than autism. The claim proceeds on the basis of the accepted disabilities only.

Direct Discrimination(disability)not determined

This preliminary hearing only determined disability status in relation to autism. The substantive discrimination claims based on the accepted disabilities (fibromyalgia, PTSD, anxiety, stress) remain to be heard at the final hearing scheduled for February 2026.

Failure to Make Reasonable Adjustments(disability)not determined

This preliminary hearing only determined disability status in relation to autism. The substantive reasonable adjustments claims based on the accepted disabilities remain to be heard at the final hearing scheduled for February 2026.

Indirect Discrimination(disability)not determined

This preliminary hearing only determined disability status in relation to autism. The substantive indirect discrimination claims based on the accepted disabilities remain to be heard at the final hearing scheduled for February 2026.

Harassment(disability)not determined

This preliminary hearing only determined disability status in relation to autism. The substantive harassment claims based on the accepted disabilities remain to be heard at the final hearing scheduled for February 2026.

Victimisation(disability)not determined

This preliminary hearing only determined disability status in relation to autism. The substantive victimisation claims based on the accepted disabilities remain to be heard at the final hearing scheduled for February 2026.

Facts

The claimant worked as a work coach for DWP since 1998. She has multiple health conditions including fibromyalgia, PTSD, anxiety and stress (accepted as disabilities by respondent). She also claimed to be disabled due to autism, carpal tunnel syndrome, asthma and long Covid. The claimant withdrew claims relating to carpal tunnel, asthma and long Covid. A therapist recommended autism assessment in December 2023 but no formal diagnosis had been made. The claimant identified various impairments including sleep difficulties, sensory issues, social difficulties which she attributed to autism.

Decision

The tribunal found the claimant was not disabled by reason of autism at the relevant time. While the claimant demonstrated several impairments with substantial and long-term effects on day-to-day activities, the medical evidence supported these being attributable to her already-accepted disabilities (fibromyalgia, PTSD, anxiety, stress) rather than autism. The disability discrimination claims will proceed based on the accepted disabilities only.

Practical note

Without formal diagnosis, establishing autism as a disability requires clear medical evidence distinguishing autism-related impairments from those caused by overlapping conditions, particularly where other mental health disabilities are already accepted.

Legal authorities cited

J v DLA Piper UK LLP [2010] ICR 1052Chacon Navas v Eurest Colectividades SA C-13/05 [2006] IRLR 706Z v A Department C-363/12 [2014] IRLR 563Igweike v TSB Bank Plc [2020] IRLR 267Walker v Sita Information Networking Computing Ltd UKEAT/0097/12Patel v Metropolitan Borough Council [2010] IRLR 280Aderemi v London and South Eastern Railway Ltd [2013] ICR 591Goodwin v Patent Office [1999] ICR 302Royal Bank of Scotland plc v Morris [2011] UKEAT/0436/10/MAAJC v Gordonstoun Schools Limited [2016] CSIH 32

Statutes

Equality Act 2010 Schedule 1European Framework Directive 2000/78/ECEquality Act 2010 s.6Equality Act 2010 (Amendment) Regulations 2023 SI 2023/1425Equality Act 2010 s.15Equality Act 2010 ss.20 & 21Equality Act 2010 s.19Equality Act 2010 s.26Equality Act 2010 s.27Equality Act 2010 s.212

Case details

Case number
2403387/2024
Decision date
16 May 2025
Hearing type
preliminary
Hearing days
1
Classification
contested

Respondent

Sector
central government
Represented
Yes
Rep type
barrister

Employment details

Role
Work coach

Claimant representation

Represented
Yes
Rep type
barrister