Cases2400496/2024

Claimant v Manchester Airport Plc

2 May 2025Before Employment Judge BarkerManchesterremote video

Outcome

Claimant fails

Individual claims

Discrimination Arising from Disability (s.15)(disability)struck out

Claims struck out under Rule 38(1)(b) due to the claimant's scandalous, unreasonable and vexatious conduct including making criminal threats of violence against the second respondent, causing her to refuse to attend to give evidence, rendering a fair trial impossible.

Harassment(disability)struck out

Struck out for the same reasons as the disability discrimination claim - claimant's conduct including threats and violence prevented the second respondent from attending as a witness.

Direct Discrimination(disability)struck out

The claimant sought to amend to add this claim but all claims were struck out due to his conduct in the proceedings which made a fair trial impossible.

Failure to Make Reasonable Adjustments(disability)struck out

The claimant sought to amend to add this claim but all claims were struck out due to his conduct in the proceedings.

Victimisation(disability)struck out

The claimant sought to amend to add this claim but all claims were struck out due to his conduct in the proceedings.

Facts

The claimant was employed as an aviation security officer and was suspended in July 2023 due to concerns about his use of medicinal cannabis. Following an incident with his line manager (the second respondent) on 26 September 2023, he was suspended again, raised a grievance which was rejected, and resigned in January 2024. He then brought disability discrimination claims. Between June and August 2024 the claimant sent a series of increasingly threatening emails to both respondents, including threats to physically harm the second respondent, and on 5 August 2024 he attended the airport with a knife and caused criminal damage, for which he was convicted.

Decision

The tribunal struck out all claims under Rule 38(1)(b) because the claimant's conduct was scandalous, unreasonable and vexatious. The second respondent refused to attend to give evidence due to fear and diagnosed post-traumatic stress from the claimant's threats and violence. The tribunal found a fair trial was impossible without her evidence, and that the only proportionate response was to strike out the claims.

Practical note

Parties who engage in criminal threats and violence against respondents during tribunal proceedings will lose their right to have their claims heard, as such conduct makes a fair trial impossible and amounts to an abuse of the tribunal process.

Legal authorities cited

Force One Utilities v Hatfield UKEAT/0048/08Gainford Care Homes v Tipple and Roe [2016] EWCA Civ 382Bolch v Chipman UKEAT/1149/02

Statutes

Employment Tribunals Rules of Procedure 2024 Rule 38(1)(b)Employment Tribunals Rules of Procedure 2024 Rule 38(1)(a)

Case details

Case number
2400496/2024
Decision date
2 May 2025
Hearing type
strike out
Hearing days
1
Classification
procedural

Respondent

Sector
transport
Represented
Yes
Rep type
barrister

Employment details

Role
Aviation Security Officer
Service
8 months

Claimant representation

Represented
No