Cases6001516/2024

Claimant v Wessex Retail Ltd

4 April 2025Before Employment Judge GorajExeterremote video

Outcome

Claimant fails

Individual claims

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

The tribunal found that the claimant was not a disabled person within the meaning of section 6 of the Equality Act 2010 during the relevant period. The tribunal concluded that his contended impairments (lower back pain, hearing issues, neurodiverse conditions, and depression) did not have a substantial adverse effect on his ability to carry out normal day-to-day activities. Without disability status, the discrimination claims could not proceed.

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

This claim failed because the claimant did not satisfy the threshold requirement of being a disabled person under section 6 of the Equality Act 2010 at the relevant time.

Failure to Make Reasonable Adjustments(disability)failed

This claim failed because the claimant did not satisfy the threshold requirement of being a disabled person under section 6 of the Equality Act 2010 at the relevant time.

Harassment(disability)failed

This claim failed because the claimant did not satisfy the threshold requirement of being a disabled person under section 6 of the Equality Act 2010 at the relevant time.

Facts

Mr Stutt was employed as a store assistant by Wessex Retail Ltd from February 2023 until his dismissal on 3 June 2024 following sickness absence. He brought disability discrimination claims relying on multiple impairments: lower back pain, hearing loss in his left ear, undiagnosed neurodiverse conditions (ADHD, OCD, Aspergers/autism, Ehlers-Danlos Syndrome), and depression. He contended that his personality and neurodiverse traits led to friction with management and colleagues, culminating in discriminatory treatment and dismissal. The respondent denied he was disabled within the meaning of the Equality Act 2010.

Decision

The tribunal held a preliminary hearing to determine whether the claimant was a disabled person under section 6 of the Equality Act 2010. It found that none of his contended impairments (individually or cumulatively) had a substantial adverse effect on his ability to carry out normal day-to-day activities during the relevant period. The tribunal noted a lack of medical evidence supporting formal diagnoses, and concluded that the claimant's personality traits and work-related stress did not meet the statutory threshold. Consequently, all disability discrimination claims were dismissed and the final hearing vacated.

Practical note

A claimant must establish disability status with clear medical evidence showing substantial adverse effects on day-to-day activities; personality traits, work frustrations, and undiagnosed conditions do not satisfy the statutory definition of disability under the Equality Act 2010.

Legal authorities cited

Goodwin v Patent Office [1999] ICR 302Rugamer v Sony Music Entertainment UK Ltd [2002] ICR 381Hill v Clacton Family Trust Ltd [2005] EWCA CivDLA Piper UK LLP UKEAT/0263/09Gordonstoun Schools Ltd [2016] CSIH 32

Statutes

Equality Act 2010 s.21Equality Act 2010 Sch.1Equality Act 2010 s.26Equality Act 2010 s.6Equality Act 2010 s.15Equality Act 2010 s.20

Case details

Case number
6001516/2024
Decision date
4 April 2025
Hearing type
preliminary
Hearing days
1
Classification
contested

Respondent

Sector
retail
Represented
Yes
Rep type
barrister

Employment details

Role
store assistant
Service
1 years

Claimant representation

Represented
No