Cases8001205/2024

Claimant v National Oilwell Varco UK Limited

20 February 2025Before Employment Judge J M HendryScotlandremote video

Outcome

Other

Individual claims

Constructive Dismissalnot determined

The substantive claim for constructive unfair dismissal remains live and has not yet been heard on its merits. This preliminary hearing dealt only with the claimant's application to amend to add discrimination claims, which was refused.

Facts

The claimant, a Polish engineer, resigned on 29 May 2024 following difficulties with management including being placed on a performance improvement plan (PIP), issues with holiday requests, and grievance handling. He filed a claim for constructive unfair dismissal on 9 August 2024. He then made two separate applications to amend his claim to add race discrimination complaints, first on 15 October 2024 (claiming discrimination by perception as an 'outsider'), and again on 24 November 2024 (claiming direct and indirect race discrimination based on Polish nationality). Both amendment applications were refused.

Decision

The tribunal refused the claimant's second application to amend his claim to add race discrimination allegations. The judge found the proposed claims were out of time, lacked reasonable prospects of success as the claimant could point to no evidence from which race could be inferred as a motive for treatment, would cause significant prejudice to the respondent through increased complexity and cost, and the balance of hardship favoured the respondent. The constructive dismissal claim remains to be heard.

Practical note

An application to add out-of-time discrimination claims will be refused where the claimant cannot identify facts from which discrimination could be inferred beyond mere differences in treatment, particularly where allowing the amendment would significantly increase the complexity and cost of defending the proceedings.

Legal authorities cited

Madarassy v Nomura International Plc [2007] ICR 867Selkent Bus Co Ltd v Moore [1996] ICR 836Abercrombie v Aga Rangemaster Ltd [2014] ICR 209Vaughan v Modality Partnership [2021] ICR 535Chief Constable of Norfolk v Coffey

Statutes

Equality Act 2010

Case details

Case number
8001205/2024
Decision date
20 February 2025
Hearing type
preliminary
Hearing days
1
Classification
contested

Respondent

Sector
energy
Represented
Yes
Rep type
solicitor

Employment details

Role
Engineer

Claimant representation

Represented
No