Cases2304472/2023

Claimant v Secretary of State for Justice

16 May 2025Before Employment Judge HartLondon Southhybrid

Outcome

Partly successful

Individual claims

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

The tribunal found that being issued with a final written warning on 18 October 2023 was unfavourable treatment because of something arising in consequence of disability. The claimant's absences had reached an adjusted trigger point due to her disability conditions of anxiety, depression, and long Covid, and the warning constituted discrimination arising from disability.

Discrimination Arising from Disability (s.15)(disability)failed

The claimant brought other complaints of disability discrimination which did not succeed at the liability hearing on 10-14 March 2025. The tribunal provided oral reasons at that hearing explaining why those complaints failed.

Facts

Ms Tyrell, employed by the Ministry of Justice as Operations Manager since June 2020, suffers from disability (anxiety, depression, and long Covid). Following sickness absence due to her conditions, she was issued with a final written warning on 18 October 2023 for reaching adjusted trigger points. She succeeded at a liability hearing in establishing this warning constituted discrimination arising from disability. At the remedy hearing, the respondent applied to strike out or impose a deposit order on her personal injury claim (seeking £15,200 for psychiatric damage) on grounds of no or little reasonable prospect of success.

Decision

The tribunal refused the respondent's applications to strike out or impose a deposit order on the personal injury claim. While accepting the medical evidence was mixed and the GP records and medication history did not clearly support the claimant's case, the tribunal found the evidence was not conclusively against her. A KCH letter noted increased stress could trigger long Covid inflammation, and her recovery took longer than anticipated pre-warning. This raised complex questions of medical causation requiring expert evidence, and the case was not hopeless.

Practical note

Even at remedy stage, tribunals will not strike out personal injury claims for disability discrimination unless the evidence conclusively disproves causation; mixed medical evidence and questions requiring expert testimony will survive strike-out applications.

Legal authorities cited

Patel v Lloyds Pharmacy Ltd (UKEAT/0418/12)Anyanwu v South Bank Students' Union and South Bank University [2001] IRLR 305Ezsias v North Glamorgan NHS Trust [2007] ICR 1126Mechkarov v Citibank NA [2016] ICR 1121

Statutes

Equality Act 2010

Case details

Case number
2304472/2023
Decision date
16 May 2025
Hearing type
remedy
Hearing days
3
Classification
contested

Respondent

Name
Secretary of State for Justice
Sector
central government
Represented
Yes
Rep type
barrister

Employment details

Role
Operations Manager
Service
5 years

Claimant representation

Represented
No