Cases4104696/2024

Claimant v Arnold Clark Automobile Limited

14 March 2025Before Employment Judge P O'DonnellScotlandin person

Outcome

Claimant fails

Individual claims

Failure to Make Reasonable Adjustments(disability)failed

The tribunal found that while the duty to make reasonable adjustments was engaged in respect of the first PCP (fixed working hours), the proposed adjustment (finishing one hour early three days a week) was not reasonable because it was not clear it would overcome the disadvantage and would have disrupted the respondent's operations significantly. In respect of the second PCP (flexible working policy and armed forces covenant), the tribunal found the duty was not engaged as no decision had been made refusing time off for therapy appointments and the claimant was not actually subjected to any disadvantage in this respect.

Facts

The claimant, a car valet with PTSD from his army service, worked fixed hours 8am to 5.30pm for the respondent. He requested flexible working to finish one hour early three days a week to attend the gym, which he used to manage his PTSD. The respondent refused, citing business needs as they had high volumes of cars (124-231 daily) to clean with a team of 6 valets and increased volumes in the afternoon. The claimant also alleged he was refused time off for therapy appointments, though no appointments had been arranged at the relevant time. He resigned on 30 August 2024 citing failure to make reasonable adjustments.

Decision

The tribunal found the duty to make reasonable adjustments was engaged regarding the fixed working hours PCP, but the proposed adjustment was not reasonable as there was insufficient evidence it would overcome the disadvantage and it would significantly disrupt the respondent's operations. For the second PCP regarding therapy appointments, the tribunal found the duty was not engaged as no decision refusing time off had actually been made and the claimant was not subjected to the disadvantage alleged. All claims were dismissed.

Practical note

An employer's refusal to implement a proposed reasonable adjustment can be justified where there is insufficient evidence the adjustment would overcome the disadvantage and where there is clear evidence of significant operational disruption to the business, particularly in high-volume operational environments.

Legal authorities cited

Armitage, Marsden and HM Prison Service v Johnson [1997] IRLR 162Smith v Churchills Stairlifts plc [2006] ICR 524O'Hanlon v Revenue and Customs Comrs [2007] IRLR 404

Statutes

Equality Act 2010 s.21Equality Act 2010 s.6Equality Act 2010 s.20Equality Act 2010 s.212(2)

Case details

Case number
4104696/2024
Decision date
14 March 2025
Hearing type
full merits
Hearing days
3
Classification
contested

Respondent

Sector
retail
Represented
Yes
Rep type
solicitor

Employment details

Role
Car Valet
Service
10 months

Claimant representation

Represented
Yes
Rep type
lay rep