Cases3304494/2024

Claimant v SDL Surveying Ltd

27 March 2025Before Employment Judge S MooreEast of Englandin person

Outcome

Other

Individual claims

Unfair Dismissalnot determined

This claim remains in the case and will proceed to full hearing in November 2026. The preliminary hearing only addressed an amendment application and did not determine the merits of the existing claims.

Automatic Unfair Dismissalnot determined

This claim is based on allegations of protected disclosures regarding breaches of RICS rules and working outside geographical competence. It remains undetermined and will proceed to full hearing.

Detrimentnot determined

This whistleblowing detriment claim relates to alleged protected disclosures about RICS compliance. It remains undetermined and will proceed to full hearing.

Direct Discrimination(disability)not determined

This disability discrimination claim remains in the case and will proceed to full hearing. The preliminary hearing did not address its merits.

Indirect Discrimination(disability)not determined

This claim concerns whether the claimant's sickness absence (arising from lymphoma) put him at particular disadvantage in the redundancy selection process. It remains undetermined and will proceed to full hearing.

Discrimination Arising from Disability (s.15)(disability)not determined

The original s.15 claim was based on sickness absence arising from disability affecting redundancy scoring. This claim remains in the case and will proceed to full hearing. The claimant's application to amend to add a separate s.15 claim based on report turnaround times was refused.

Facts

The claimant was employed as a surveyor from March 2013 to January 2024 when dismissed for redundancy. He has lymphoma and brought claims including unfair dismissal, whistleblowing, and disability discrimination. The original disability discrimination claims focused on sickness absence affecting redundancy selection. The claimant applied to amend to add a new s.15 claim alleging that his report turnaround times (affected by fatigue, memory loss, insomnia and anxiety from his disability) led to lower redundancy scores, relying on communications with the employer dating back to 2017 about performance impacts.

Decision

The tribunal refused the amendment application. Judge Moore determined this was a new claim rather than further particulars, requiring substantial new factual inquiries going back to 2017. Despite the hearing being distant (November 2026), the amendment was very much out of time (claim filed April 2024, amendment sought January 2025) with no explanation for delay. The balance of prejudice favoured refusal, given the respondent would face evidence about matters up to nine years old, while the claimant already had seven extensive heads of claim.

Practical note

Late amendment applications to add new disability discrimination claims based on different factual allegations will be refused where legally represented claimants provide no explanation for delay and the amendments would significantly widen the factual scope requiring evidence of events many years old.

Legal authorities cited

Selkent Bus Company Ltd v Moore [1996] ICR 826Vaughan v Modality Partnership UK [2021] ICR 535

Statutes

Equality Act 2010 s.15

Case details

Case number
3304494/2024
Decision date
27 March 2025
Hearing type
preliminary
Hearing days
1
Classification
contested

Respondent

Sector
professional services
Represented
Yes
Rep type
barrister

Employment details

Role
Surveyor
Service
11 years

Claimant representation

Represented
Yes
Rep type
barrister