Cases8002100/2024

Claimant v Fedcap Employment Scotland Limited

30 April 2025Before Employment Judge J M HendryScotlandremote video

Outcome

Claimant fails

Individual claims

Unfair Dismissalstruck out

Claim struck out as time-barred. The tribunal found the claimant failed to demonstrate it was not reasonably practicable to file on time. She was capable, had internet access, knowledge of time limits, and opportunities to file despite caring for her husband. She chose to prioritise other matters.

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

Claim struck out as time-barred. The tribunal found the claimant failed to demonstrate it was just and equitable to extend time. Although she had caring responsibilities and her own health issues, she was capable and had opportunities to file within the deadline but chose not to prioritise it.

Facts

The claimant was dismissed on capability grounds due to ill health on 17 June 2024. She had a long-standing heart condition and lost her hair due to medication, impacting her mental health. She was supported by UNISON at dismissal and appeal meetings. Her husband suffered serious spinal injuries and multiple falls requiring intensive care. She filed her ET claim on 11 December 2024, 19 days after the extended deadline of 22 November 2024. She stated she forgot to file because she was focused on caring for her severely disabled husband.

Decision

The tribunal dismissed both the unfair dismissal and disability discrimination claims as time-barred. The tribunal found the claimant was a capable person with internet access and knowledge of time limits who had opportunities to file on time despite her husband's health issues and her own anxiety. She chose to prioritise other matters and this did not make it not reasonably practicable to file, nor was it just and equitable to extend time.

Practical note

Even sympathetic personal circumstances (caring for a seriously ill spouse, own mental health issues) will not save a late claim where the claimant was objectively capable of filing on time and chose to prioritise other matters.

Legal authorities cited

Asda Stores Ltd v Kauser EAT 0165/07Keeble v British Coal Corporation [1997] IRLR 336Robertson v Bexley Community Centre [2003] IRLR 434Wall's Meat Co Ltd v Khan [1979] ICR 52Palmer v Southend Borough Council [1984] ICR 372Jones v Sec of State for Health and Social CarePorter v Bandridge Ltd [1978] ICR 943Dedman v British Building & Engineering Appliances Ltd [1974] ICR 53Chief Constable of Lincolnshire Police v Caston [2009] EWCA Civ 1298Abertawe Bro Morgannwg University Local Health Board v Morgan [2018] ICR 194Southwark London Borough Council v Afolabi [2003] ICR 800Kumari v Greater Manchester Mental Health NHS Foundation Trust [2022] EAT 132

Statutes

Limitation Act 1980Equality Act 2010 s.123Employment Rights Act 1996 s.111

Case details

Case number
8002100/2024
Decision date
30 April 2025
Hearing type
preliminary
Hearing days
1
Classification
contested

Respondent

Sector
professional services
Represented
Yes
Rep type
solicitor

Employment details

Role
Adviser

Claimant representation

Represented
No