Cases1401847/2022

Claimant v Castle Construction (Cheltenham) Ltd

9 April 2025Before Employment Judge LiveseyBristolin person

Outcome

Claimant fails

Individual claims

Automatic Unfair Dismissalfailed

The tribunal found the claimant was dismissed because of identified health and safety failings uncovered during his absence, not because he made public interest disclosures. No protected disclosures were found to have been made or, if made, they were not the reason for dismissal.

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

The tribunal found no direct discrimination. The claimant was treated as he was because of conduct/performance issues, not because of his disabilities (Long Covid and visual impairment). A hypothetical non-disabled employee would have been treated the same way.

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

The tribunal found the unfavourable treatment (investigatory meetings, disciplinary process, dismissal) did not arise from the claimant's Long Covid. The process was triggered by identified health and safety failings, not his absence or disability-related matters.

Failure to Make Reasonable Adjustments(disability)failed

The tribunal found that alleged PCPs either did not exist, did not cause substantial disadvantage, or reasonable adjustments were in fact offered (meetings by video/telephone/in writing, extended deadlines). The claimant was able to engage fully with the processes.

Victimisationfailed

The tribunal found the alleged detriments (time limits, refusal of neutral venue, failure to investigate grievances fully, contact restrictions) were not caused by the protected acts. Treatment was motivated by volume/manner of grievances and the claimant's conduct, not the fact he raised discrimination allegations.

Facts

The claimant was employed as Health and Safety Manager from May 2020. He went off sick in August 2021 with Covid-19, which developed into Long Covid. During his absence, the respondent discovered multiple serious health and safety failings across their hotel and construction businesses, including failures in fire safety, legionella testing, and PAT testing. A disciplinary process was commenced in February 2022. The claimant raised multiple grievances (ultimately 14+) and allegations of discrimination. He was dismissed in March 2022 for gross misconduct. The claimant had Long Covid and visual impairment (loss of vision in right eye, partial loss in left).

Decision

The tribunal dismissed all claims. It found the claimant was dismissed because of substantiated health and safety failures, not because of disability or protected disclosures. The tribunal found the respondent offered reasonable adjustments (meetings by video/phone/writing, extended deadlines) and the claimant was able to engage with processes. The volume and manner of grievances, not their content, explained any adverse treatment. The tribunal applied Martin v Devonshire Solicitors, finding the manner of conduct broke the causal chain for victimisation.

Practical note

An employer can fairly dismiss for serious health and safety failings discovered during sick leave, even where the employee has disabilities, provided the dismissal is genuinely motivated by the failings and reasonable adjustments are offered to enable engagement with disciplinary processes; the volume and manner of grievances can break the causal chain in victimisation claims.

Legal authorities cited

Project Management Institute v LatifNagarajan v London Regional Transport [2000] 1 AC 501Environment Agency v Rowan [2008] ICR 218Madarassy v Nomura International Plc [2007] ICR 867Igen v Wong [2005] ICR 931Warburton v Chief Constable of Northamptonshire Police [2022] EAT 42Martin v Devonshire Solicitors [2011] ICR 352Ishola v Transport for London [2020] EWCA Civ 112Shamoon v Royal Ulster Constabulary [2003] UKHL 11Law Society v Bahl [2004] EWCA Civ 1070

Statutes

Equality Act 2010 s.15Equality Act 2010 s.13Equality Act 2010 s.136Equality Act 2010 s.123Equality Act 2010 s.108Equality Act 2010 s.27Equality Act 2010 s.21Equality Act 2010 s.20

Case details

Case number
1401847/2022
Decision date
9 April 2025
Hearing type
full merits
Hearing days
8
Classification
contested

Respondent

Sector
construction
Represented
Yes
Rep type
lay rep

Employment details

Role
Health and Safety Manager
Service
2 years

Claimant representation

Represented
No