Cases1405576/2023

Claimant v Swindon Borough Council

23 April 2025Before Employment Judge OliverBristolremote video

Outcome

Claimant fails

Individual claims

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

The tribunal found that although the respondent treated the claimant unfavourably by applying the absence management policy and dismissing him, and this was because of something arising from his disability (sickness absence caused by Epstein-Barr virus), the treatment was a proportionate means of achieving legitimate aims. The claimant had 255 days of sickness absence over two years. The tribunal found that allowing the claimant to work from home five days per week would not have alleviated the high levels of sickness absence, as evidenced by 35 days absence during a period when he was working fully from home. The respondent's aims of managing absence, maintaining customer service, and supporting the team outweighed the discriminatory effect, and there were no adjustments that would have meaningfully improved the situation.

Facts

The claimant was a customer information guide employed by the council from 2008 to 2023. He developed Epstein-Barr virus in 2020, causing chronic fatigue and brain fog. He was absent for 255 days over two years due to the condition. Occupational health repeatedly recommended working from home. The respondent initially allowed him to work from home two days per week, but after serious IT/telephone issues during the pandemic, required all staff to return to the office. The claimant was dismissed in May 2023 after the absence management policy was applied through stages 1-3.

Decision

The tribunal found that although the respondent's treatment was unfavourable and because of something arising from the claimant's disability, it was a proportionate means of achieving legitimate aims. The tribunal concluded that allowing the claimant to work from home five days per week would not have reduced his very high sickness absence levels, as evidenced by his absence record when he did work fully from home. The respondent's needs to maintain its critical public telephone service outweighed the discriminatory effect.

Practical note

A failure to implement occupational health recommendations for adjustments will not always defeat a proportionality defence if the tribunal finds, on the evidence, that the adjustment would not have alleviated the disadvantage in question.

Legal authorities cited

Buchanan v Commissioner of Police of the Metropolis [2016] IRLR 918Stott v Ralli Ltd [2022] IRLR 148Department for Work and Pensions v Boyers [2022] EAT 76Chagger v Abbey National Plc [2010] ICR 397South Gloucestershire Council v Hundal [2024] EAT 140Griffiths v Secretary of State for Work and Pensions [2017] ICR 160

Statutes

Equality Act 2010 s.15

Case details

Case number
1405576/2023
Decision date
23 April 2025
Hearing type
full merits
Hearing days
5
Classification
contested

Respondent

Sector
public sector
Represented
Yes
Rep type
barrister

Employment details

Role
Customer Information Guide
Service
15 years

Claimant representation

Represented
Yes
Rep type
lay rep