Cases2302805/2023

Claimant v RefuAid

19 February 2025Before Employment Judge CawthrayLondon Centralremote video

Outcome

Claimant fails

Individual claims

Direct Discrimination(race)struck out

Struck out for complete non-compliance with tribunal case management orders. The claimant failed to provide any information clarifying the basis of her race discrimination claim despite multiple orders and warnings, making it impossible for the respondents to know the case against them or for a fair hearing to proceed.

Discrimination Arising from Disability (s.15)(disability)struck out

Struck out for complete non-compliance with tribunal case management orders. The claimant failed to provide required medical information about her claimed disability, failed to clarify the allegations, and did not comply with any orders, preventing preparation for a fair hearing.

Facts

The claimant brought claims for race and disability discrimination against a charity and three of its employees/former employees in June 2023. The basis of the claims was never made clear despite multiple case management hearings. The claimant did not attend three preliminary hearings on 7 June 2024, 10 December 2024, and 15 February 2025. Following the December 2024 hearing, Employment Judge Lumby made detailed orders requiring the claimant to clarify her claims, provide medical evidence of disability, and update her schedule of loss by 17 January 2025. The claimant failed to comply with any of these orders and provided no explanation, despite warnings that non-compliance could result in strike out.

Decision

The tribunal struck out the entire claim for complete non-compliance with case management orders under rule 38(1)(c). Employment Judge Cawthray found the magnitude of non-compliance was significant, the claim had caused disruption and prejudice to the respondents over 18 months, the claim remained so unclear that a fair hearing was impossible, and an unless order would be ineffective given the complete non-compliance despite prior warnings. Strike out was determined to be a proportionate response.

Practical note

Complete non-compliance with case management orders, particularly where a claim remains fundamentally unclear after 18 months and multiple warnings have been given, will result in strike out even for an unrepresented claimant with health issues where no medical evidence justifies the non-compliance.

Legal authorities cited

Weir Valves and Controls (UK) Ltd v Armitage 2004 ICR 371

Statutes

Employment Tribunal Procedure Rules 2024 rule 38Employment Tribunal Procedure Rules 2024 rule 3

Case details

Case number
2302805/2023
Decision date
19 February 2025
Hearing type
strike out
Hearing days
1
Classification
procedural

Respondent

Sector
charity
Represented
No

Claimant representation

Represented
No