Cases8000150/2025

Claimant v The Press Association Limited

30 April 2025Before Employment Judge I McFatridgeScotlandremote video

Outcome

Claimant fails

Individual claims

Failure to Make Reasonable Adjustments(disability)struck out

Claim struck out as time-barred. Tribunal found the claim was submitted approximately 7 months late. Time started to run in January/February 2024 when respondent acted inconsistently with making the adjustment by continuing varied shift patterns after claimant's request. Tribunal declined to extend time on just and equitable grounds, finding inadequate reasons for delay, potential prejudice to cogency of evidence, and that claimant did not act promptly despite being aware of her rights and having union representation.

Facts

Claimant was a journalist employed by respondent from August 2023, with disclosed disabilities of narcolepsy and cataplexy. She worked varied shift patterns which she contended put her at substantial disadvantage. Around January/February 2024 she requested a fixed shift pattern as a reasonable adjustment. Respondent continued rostering her on varied shifts until August 2024 when they implemented the fixed pattern. Claimant raised a grievance in September 2024, commenced ACAS early conciliation on 30 September 2024, and filed her tribunal claim on 17 January 2025.

Decision

The tribunal struck out the claim as time-barred and declined to extend time on just and equitable grounds. Time began running in January/February 2024 when the respondent acted inconsistently with making the adjustment by continuing varied shift rotas after the claimant's request. The claim was therefore approximately 7 months late. The tribunal found inadequate reasons for the delay, noting that the union's admitted administrative error in January 2025 had no causative effect as the claim was already time-barred by then.

Practical note

When time starts running in failure to make reasonable adjustments claims depends on whether the employer does an act inconsistent with making the adjustment (s.123(4)(a)) — continuing to impose the disadvantageous PCP after a request for adjustment is such an inconsistent act, even if the adjustment is later granted.

Legal authorities cited

Robertson v Bexley Community Centre [2003] IRLR 434Matuszowicz v Kingston upon Hull City Council [2009] IRLR 288Abertawe Bro Morgannwg University Local Health Board v Morgan [2018] ICR 1194Hunswick v Royal Mail Group plc EAT003/07Hawkins v Ball [1996] IRLR 258Keeble v British Coal Corporation [1997] IRLR 336

Statutes

Equality Act 2010 s.20(3)Equality Act 2010 s.123(4)Equality Act 2010 s.123(3)

Case details

Case number
8000150/2025
Decision date
30 April 2025
Hearing type
preliminary
Hearing days
1
Classification
contested

Respondent

Sector
media
Represented
Yes
Rep type
barrister

Employment details

Role
Journalist

Claimant representation

Represented
Yes
Rep type
barrister