Cases2200214/2018

Claimant v University College London Hospitals NHS Foundation Trust

16 April 2025Before Employment Judge Gordon WalkerLondon Centralremote video

Outcome

Claimant fails

Individual claims

Whistleblowingstruck out

All claims were struck out under Rule 38 for scandalous, unreasonable and vexatious conduct, failure to actively pursue the claim, and because a fair hearing was no longer possible within a reasonable time due to claimant's repeated non-cooperation, inordinate and inexcusable delay, and vilification of the respondent's solicitors.

Direct Discrimination(disability)struck out

Struck out as part of entire claim for the same reasons as the whistleblowing claim. The claimant's conduct made a fair hearing impossible within a reasonable timeframe, and there was no indication she would cooperate with case management in future.

Direct Discrimination(age)struck out

Struck out together with all other claims due to claimant's unreasonable and scandalous conduct of proceedings, including vilifying the respondent's solicitors, failure to comply with orders, and making it impossible to bring the matter to hearing in a reasonable time.

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

All claims related to the withdrawal of two job offers. The tribunal found the claimant had conducted proceedings unreasonably and scandalously, with repeated defaults and no indication of future cooperation, making a fair hearing impossible within reasonable time.

Facts

The claimant brought claims of whistleblowing detriment, direct discrimination on grounds of disability and age, and discrimination arising from disability, all relating to the respondent's withdrawal of two job offers made to her. The claims were originally filed in 2018 but had been listed for full merits hearings twice (both adjourned due to claimant's medical condition). The claimant conducted proceedings in an unreasonable manner, failing to comply with tribunal orders, making serious accusations against the respondent's solicitors, repeatedly disputing bundles, and missing deadlines. The case had already been subject to one strike out application which was partially allowed and then overturned on appeal to the EAT, which remitted the matter.

Decision

The tribunal struck out all claims under Rule 38 on the grounds that the claimant had conducted proceedings in a scandalous, unreasonable and vexatious manner, had not actively pursued the claim (inordinate and inexcusable delay previously found), and a fair hearing was no longer possible within a reasonable time. The claimant had vilified the respondent's solicitors in written submissions, failed to cooperate with case preparation, and provided no assurance of future cooperation despite being given the opportunity to do so. The tribunal found past problematic behaviour would recur and it was proportionate to strike out the entire claim.

Practical note

A claimant's persistent failure to cooperate with case management, combined with scandalous conduct including vilification of the opponent's solicitors, can justify strike out even where substantive witnesses remain available, if there is no prospect of bringing the case to hearing within reasonable time.

Legal authorities cited

De Keyser Limited v WilsonBirkett v James [1978] AC 297Arrow Nominees v Blackledge [2002] BCLC 167 CABlockbuster Entertainment Limited v James [2006] IRLR 630 CABolch v Chipman EAT/1149/02Emuemukoro v Croma Vigilant (Scotland) Limited [2022] ICR 327Mr T Smith v Tesco Stores [2023] EAT 11Bennett v Southwark London Borough Council [2002] ICR 881 CA

Statutes

Employment Tribunal Rules 2013 Rule 37Employment Tribunal Rules 2024 Rule 38

Case details

Case number
2200214/2018
Decision date
16 April 2025
Hearing type
strike out
Hearing days
2
Classification
procedural

Respondent

Sector
healthcare
Represented
Yes
Rep type
barrister

Claimant representation

Represented
No