Cases3205406/2022

Claimant v HM Revenue & Customs

14 March 2025Before Employment Judge Mr G. KingEast Londonremote video

Outcome

Claimant fails

Individual claims

Failure to Make Reasonable Adjustments(disability)failed

The tribunal found that the claimant was not at substantial disadvantage from lack of ergonomic chair, mouse, second screen or adjustable desk. For the chair, even if substantial disadvantage existed, the respondent provided it within 43 days of knowing it was needed (22 May to 4 July 2023), which was reasonable. For mouse and screens, OH assessment stated no upper limb issues and no substantial disadvantage was evidenced. For desk, OH report did not recommend it and claimant failed to raise issue for 18 months. Claimant's credibility was questioned due to inconsistent evidence about the chair's benefit.

Direct Discrimination(age)not determined

Age discrimination was listed in the claim form but was not addressed or determined at this hearing. The judgment focused solely on reasonable adjustments regarding auxiliary aids.

Victimisationnot determined

Victimisation was referenced in the claim form in relation to a previous ET claim, but was not addressed or determined at this hearing. The judgment focused solely on reasonable adjustments.

Facts

The claimant, a disabled Investigation Officer employed by HMRC, claimed the respondent failed to provide reasonable adjustments in the form of auxiliary aids: an ergonomic chair, ergonomic mouse, two screens, and an adjustable desk. The claim period began 21 April 2022 following an occupational health report. The claimant's anticipated hip operation was repeatedly postponed. An ergonomic chair was provided on 4 July 2023, 43 days after OH recommendation. A mouse and screens were provided in December 2024. An adjustable desk was never provided, as the claimant was not a contractual homeworker under internal policy. The claimant never raised a grievance despite claiming the lack of equipment amounted to 'torture'.

Decision

The tribunal dismissed all claims. For the chair, even if substantial disadvantage existed, 43 days to provide it was reasonable. For mouse and screens, the tribunal found no substantial disadvantage as OH assessment recorded no upper limb issues, and the claimant's evidence was inconsistent and not credible. For the desk, OH did not recommend it and the claimant failed to raise the issue for 18 months, indicating no real substantial disadvantage. The tribunal was critical of the claimant's failure to use internal grievance procedures.

Practical note

Employers can defeat reasonable adjustment claims by showing they did not and could not reasonably have known of substantial disadvantage; OH reports stating no issues and employee's failure to actively raise concerns for prolonged periods are strong evidence against substantial disadvantage.

Legal authorities cited

Armitage, Marsden and HM Prison Service v Johnson [1997] IRLR 162Mallon v Aecom Ltd [2021] ICR 1151Project Management Institute v Latif [2007] IRLR 579Newcastle City Council v Spires UKEAT/0034/10Leeds Teaching Hospital NHS Trust v Foster UKEAT/0552/10Conway v Community Options Ltd UKEAT/0034/12Lincolnshire Police v Weaver [2008] UKEAT 0622 07 1903

Statutes

Equality Act 2010 s.20Equality Act 2010 s.21Equality Act 2010 Schedule 8 paragraph 20

Case details

Case number
3205406/2022
Decision date
14 March 2025
Hearing type
full merits
Hearing days
3
Classification
contested

Respondent

Sector
central government
Represented
Yes
Rep type
barrister

Employment details

Role
Investigation Officer

Claimant representation

Represented
No