Cases1305842/2023

Claimant v The DPO Centre Ltd

4 March 2025Before Employment Judge BansalMidlands Westin person

Outcome

Other

Individual claims

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

This is a preliminary hearing on amendment only. The claim of direct disability discrimination regarding dismissal was allowed to be added as an amendment. The substantive merits have not yet been heard.

Victimisationnot determined

The victimisation complaint was mentioned in the grounds of resistance and is part of the ongoing proceedings, but has not yet been determined at this preliminary stage.

Harassment(disability)not determined

The claimant's application stated harassment on grounds of disability was part of her claim, but the substantive merits have not yet been heard.

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

The claimant's application stated discrimination arising from disability was part of her claim under the Equality Act 2010, but the substantive merits have not yet been heard.

Failure to Make Reasonable Adjustments(disability)not determined

The claimant's application stated failure to make reasonable adjustments was part of her claim, but the substantive merits have not yet been heard.

Facts

The claimant, who holds a first class law degree, was dismissed on 14 April 2023 by The DPO Centre Ltd. She brought claims of disability discrimination including direct discrimination, discrimination arising from disability, failure to make reasonable adjustments, victimisation and harassment. At a preliminary hearing on 10 February 2025, it became apparent that she had not expressly pleaded that her dismissal itself was an act of direct disability discrimination. She applied to amend her claim to add this. The respondents argued the claim was presented in September 2023, had been through four case management hearings focused on clarifying complaints, and that this was a new claim made 22-23 months out of time.

Decision

The tribunal allowed the claimant's application to amend her claim to include that the dismissal was an act of direct disability discrimination. The judge found this was a new cause of action but arose from the same factual matrix as existing complaints, so did not require a substantially different enquiry. The hardship to the claimant in refusing the amendment outweighed any prejudice to the respondent. The tribunal refused the second part of the amendment relating to the termination procedure as it was insufficiently particularised.

Practical note

An amendment to add a discrimination label to a dismissal already pleaded as part of the factual background may be allowed even if made significantly out of time, where it arises from the same facts and does not require substantial new investigation.

Legal authorities cited

Abercrombie v Aga Rangemaster Ltd [2013] EWCA Civ 1148Abercrombie v Aga Rangemaster Ltd [2014] ICR 20Selkent Bus Company Ltd v Moore [1996] IRLR 836Vaughan v Modality Partnership [2021] IRLR 97Ladbrokes Racing Ltd v Traynor EAT/0067/06

Statutes

Employment Tribunal Procedure Rules 2024 Rule 30Equality Act 2010 s.123(1)(b)

Case details

Case number
1305842/2023
Decision date
4 March 2025
Hearing type
preliminary
Hearing days
1
Classification
contested

Respondent

Sector
professional services
Represented
Yes
Rep type
barrister

Claimant representation

Represented
No