Cases2305256/2023

Claimant v Hanover Communications International Ltd

11 April 2025Before Employment Judge R EvansLondon Southremote video

Outcome

Claimant fails

Individual claims

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

The tribunal found that while the claimant had mental impairments of anxiety and depression which had substantial adverse effects on her ability to carry out day-to-day activities (sleeping and eating) during her employment, she failed to prove the effects were long-term. The substantial adverse effects only began during the relevant period due to work experiences and were likely to end shortly after employment ended, not lasting 12 months. No evidence showed effects would recur beyond 12 months. Therefore she was not a disabled person under s.6 Equality Act 2010.

Facts

Ms Arora was employed by Hanover Communications from 27 April to early June 2023 (approximately one month). She struggled at work and her employment was terminated. She had a history of anxiety and depression dating back to at least 2020, managed with sertraline. During her brief employment, her symptoms worsened, affecting her sleep and eating. After dismissal, she saw her GP on 1 June 2023, attributing the exacerbation to workplace treatment. She later sought assessment for possible ADHD but received no diagnosis during employment.

Decision

The tribunal found Ms Arora had mental impairments (anxiety and depression) with substantial adverse effects on sleeping and eating during employment. However, she failed to prove the long-term requirement: the substantial effects only began during the relevant period due to work stress, were likely to cease shortly after employment ended, and there was no evidence they would last 12 months or recur. Therefore she was not disabled under the Equality Act 2010 and her discrimination claim was dismissed.

Practical note

A claimant with a longstanding mental health condition may still fail to establish disability if substantial adverse effects only materialised during a brief period of employment in response to workplace stress and are likely to resolve shortly after that employment ends, as the long-term requirement focuses on the duration of effects not the underlying condition.

Legal authorities cited

McDougall v Richmond Adult Community College [2008] ICR 431Sullivan v Bury Street Capital Limited [2021] EWCA Civ 1694Goodwin v Patent Office [1999] ICR 302Cruickshank v VAW Motorcast Ltd [2002] ICR 729Morgan v Staffordshire University [2002] ICR 475J v DLA Piper UK LLP [2010] ICR 1052Igweike v TSB Bank plc [2020] IRLR 267SCA Packaging Ltd v Boyle [2009] UKHL 37

Statutes

Equality Act 2010 Sch 1 para 5Equality Act 2010 Sch 1 para 2Equality Act 2010 s.212Equality Act 2010 s.6

Case details

Case number
2305256/2023
Decision date
11 April 2025
Hearing type
preliminary
Hearing days
1
Classification
contested

Respondent

Sector
professional services
Represented
Yes
Rep type
barrister

Employment details

Service
1 months

Claimant representation

Represented
Yes
Rep type
barrister