Cases1807734/2023

Claimant v Cityroad Limited (in Creditors Voluntary Liquidation)

27 February 2025Before Employment Judge AyreSheffieldin person

Outcome

Partly successful£2,000

Individual claims

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

The tribunal found that the claimant was excluded from meetings and had his responsibilities reduced because the respondent believed he had resigned on 23 June 2023, not because of the GP note related to his disability. The unfavourable treatment was not because of something arising from his disability.

Failure to Make Reasonable Adjustments(disability)failed

The tribunal found that requiring the claimant to undertake the full range of duties as a recruitment consultant did not place him at a substantial disadvantage compared to someone without his disability. The difficulties he experienced were due to the unstructured nature of the respondent's business, not the application of the PCP. The claimant was an experienced recruitment consultant capable of doing the full range of duties.

Harassment(disability)succeeded

The tribunal found that a comment made by Mr Brewster in late July 2023 saying 'no one likes you; no one respects you, you're crazy' was unwanted conduct related to disability (the words 'you're crazy' referenced the claimant's mental health). It had the effect of creating a degrading, humiliating and offensive environment for the claimant. The other two harassment allegations (exclusion from meetings) failed as they were not related to disability.

Facts

The claimant, who has bipolar disorder, worked as a recruitment consultant for the respondent from May to September 2023. He disclosed his disability at interview. In June 2023 he provided a GP note about his mental health. On 23 June 2023 the respondent believed the claimant had resigned and excluded him from meetings and reduced his responsibilities, though he continued working until September. In late July 2023, the owner Mr Brewster said to the claimant 'no one likes you; no one respects you, you're crazy'. The respondent went into liquidation and did not defend the claim.

Decision

The tribunal found the claimant was disabled by reason of bipolar disorder. The discrimination arising from disability and reasonable adjustments claims failed because the exclusion from meetings was due to the respondent's belief the claimant had resigned, not his disability, and the PCP did not place him at substantial disadvantage. The harassment claim succeeded in relation to the 'you're crazy' comment, which related to disability and created a degrading environment. The tribunal awarded £2,000 for injury to feelings at the lower end of the lower Vento band.

Practical note

A one-off offensive comment referencing mental health ('you're crazy') can constitute disability harassment even where other allegations fail, but will attract a modest award at the lower end of the Vento scale if it is an isolated incident with limited ongoing impact.

Award breakdown

Injury to feelings£2,000

Vento band: lower

Award equivalent: 2.1 weeks' gross pay

Legal authorities cited

Aderemi v London and South Eastern Railway Ltd [2013] ICR 591Goodwin v Patent Office [1999] ICR 302Rugamer v Sony Music Entertainment UK Ltd [2011] IRLR 664Kapadia v London Borough of Lambeth [2000] IRLR 699Secretary of State for Justice v Dunn EAT 0234/16Richmond Pharmacology v Dhaliwal [2009] ICR 724Hartley v Foreign and Commonwealth Office Services [2016] ICR D17Warby v Wunda Group plc EAT 0434/11Barton v Investec Henderson Crosthwaite Securities Ltd [2003] ICR 1205Vento v Chief Constable of West Yorkshire Police (No. 2) 2003 ICR 318Simmons v Castle [2012] EWCA Civ 1288Igen v Wong [2005] ICR 931

Statutes

Equality Act 2010 s.21Equality Act 2010 s.26Equality Act 2010 s.123Equality Act 2010 s.124Equality Act 2010 s.119Equality Act 2010 s.136Equality Act 2010 s.6Equality Act 2010 s.15Equality Act 2010 s.20

Case details

Case number
1807734/2023
Decision date
27 February 2025
Hearing type
full merits
Hearing days
1
Classification
contested

Respondent

Sector
professional services
Represented
No

Employment details

Role
Recruitment Consultant
Salary band
£50,000–£60,000
Service
4 months

Claimant representation

Represented
No