Cases1404086/2020

Claimant v GreenSquare Group Ltd

21 March 2025Before Employment Judge LiveseyBristolhybrid

Outcome

Claimant fails

Individual claims

Victimisationfailed

The tribunal found that while the claimant had done protected acts (grievances alleging disability discrimination, ACAS referrals), the dismissal was not because of those acts. The overwhelming reason for dismissal was poor performance, deteriorating through 2019-2020, along with poor attitude and attendance. Mr Lillis's reference to the claimant as a 'complainer' related to the manner and frequency of complaints generally, not their protected Equality Act content. The tribunal concluded the protected acts were not an effective or substantial cause of dismissal.

Facts

Claimant, a Community Involvement Officer for a housing provider from May 2018 to April 2020, had declared Asperger's syndrome on appointment but needed no adjustments initially. Performance issues emerged from early 2019, compounded by disputes over travel expenses and failure to secure internal promotions. He raised grievances in November and December 2019 alleging disability discrimination and contacted ACAS twice. After poor performance ratings and 17% sickness absence, he was dismissed by HR on 8 April 2020 without formal procedure, with reference to poor performance, attendance and attitude, and being a 'complainer'. His appeal was rejected.

Decision

The tribunal dismissed the victimisation claim. While the claimant had done protected acts (grievances alleging disability discrimination and ACAS referrals), and the dismissal process was poor, the tribunal found the real reason for dismissal was consistently poor performance documented from 2019, combined with poor attendance (17% absence) and attitude. The reference to being a 'complainer' related to the manner and frequency of complaints generally, not their protected Equality Act content, following Martin v Devonshire.

Practical note

Even where dismissal is procedurally flawed and occurs after protected acts, a victimisation claim will fail if the employer can show that poor performance, not the protected acts themselves, was the real and substantial reason for dismissal.

Legal authorities cited

Chagger v Abbey National Plc [2010] ICR 397Chief Constable of Greater Manchester Constabulary v Bailey [2017] EWCA Civ 425Warburton v Chief Constable of Northamptonshire Police [2022] EAT 42Martin v Devonshire Solicitors [2011] ICR 352Woodhouse v West North West Homes Leeds Ltd [2013] UKEAT/0007/12Nagarajan v London Regional Transport [2000] 1 AC 501Igen v Wong [2005] ICR 931

Statutes

Equality Act 2010 s.27Equality Act 2010 s.136

Case details

Case number
1404086/2020
Decision date
21 March 2025
Hearing type
full merits
Hearing days
3
Classification
contested

Respondent

Sector
real estate
Represented
Yes
Rep type
barrister

Employment details

Role
Community Involvement Officer
Service
2 years

Claimant representation

Represented
No