Cases3309480/2023

Claimant v Secretary of State for Work and Pensions

14 March 2025Before Employment Judge E P Morgan KCWatfordremote video

Outcome

Partly successful£24,236

Individual claims

Unfair Dismissalsucceeded

Dismissal fell outside range of reasonable responses due to failure to refer claimant to DWP long covid clinic. Respondent failed to follow its own highly relevant policy. Dismissing manager and appeal officer failed to appreciate importance of applying policy even at late stage. Any reasonable employer would have applied this policy.

Direct Discrimination(disability)withdrawn

Withdrawn by claimant on first day of February 2025 hearing

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

Respondent treated claimant unfavourably by dismissing her and by not referring her to DWP long covid clinic from 11 October 2022, something arising from her disability (her absence). This was not a proportionate means of achieving legitimate aim. Need to have employee performing duties did not override need to allow claimant benefit of respondent's own policy.

Failure to Make Reasonable Adjustments(disability)failed

Claimant unfit to work throughout two year absence with no return 'on the horizon'. No prospect that proposed adjustments (referral to DWP clinic or adjusting attendance levels) would enable return to work. Duty not triggered per McHugh - no reasonable adjustment could work when no prospect of return.

Breach of Contractwithdrawn

Sum agreed during 2024 hearing, payment made in February 2025 salary run, claim withdrawn by claimant

Unlawful Deduction from Wageswithdrawn

Sum agreed during 2024 hearing, payment made in February 2025 salary run, claim withdrawn by claimant

Facts

Claimant, a part-time Work Coach employed since 2012 with pre-existing pulmonary embolisms, contracted Covid in January 2021 developing POTS and Long Covid. She remained continuously absent and unfit for work for over two years. In December 2021 Occupational Health recommended referral to DWP's Long Covid Clinic but manager failed to action this. Despite receiving extensive NHS treatment she showed no material improvement. She was dismissed in February 2023 for capability after being referred to decision-maker in October 2022.

Decision

Tribunal found dismissal unfair because respondent failed to refer claimant to its own DWP Long Covid Clinic as recommended by OH and required by policy. Discrimination arising from disability claim succeeded on same basis - failure was not proportionate means of achieving legitimate aim. Reasonable adjustments claim failed as claimant had no prospect of returning to work so duty not triggered. Claimant awarded basic award plus injury to feelings but no loss of earnings as would have been fairly dismissed three months later after clinic involvement.

Practical note

An employer's failure to follow its own relevant policy supporting disabled employees, particularly one specifically designed for the employee's condition (long covid clinic referral), will render a capability dismissal unfair even where the employee has been absent for two years with no prospect of imminent return.

Award breakdown

Basic award£8,715
Compensatory award£500
Injury to feelings£13,000
Loss of statutory rights£500
Interest£2,522

Vento band: middle

Legal authorities cited

Armitage, Marsden and HM Prison Service v Johnson [1997] IRLR 162Ministry of Defence v Cannock [1994] ICR 918Da'Bell v NSPCC [2010] IRLR 19Simmons v Castle [2012] EWCA Civ 1288De Souza v Vinci Construction [2018] ICR 433NHS Scotland v McHugh EATS 0010/06Home Office v Collins [2005] EWCA Civ 598Brown v HMRC ET 2510511/09Doran v DWP EAT 0017/14London Underground v Vuoto UKEAT/0123/09Royal Bank of Scotland v O'Doherty UKEAT/0307/14Vento v Chief Constable of West Yorkshire Police [2003] ICR 318

Statutes

Equality Act 2010 s.13Employment Rights Act 1996 Part XEquality Act 2010 s.15Equality Act 2010 s.20Equality Act 2010 s.124Equality Act 2010 s.119

Case details

Case number
3309480/2023
Decision date
14 March 2025
Hearing type
full merits
Hearing days
9
Classification
contested

Respondent

Sector
central government
Represented
Yes
Rep type
barrister

Employment details

Role
Work Coach
Service
11 years

Claimant representation

Represented
Yes
Rep type
barrister