Cases6008931/2024

Claimant v Capital City College Group

10 February 2025Before Employment Judge KeoghLondon Central

Outcome

Claimant fails

Individual claims

Unfair Dismissalstruck out

Tribunal found it was reasonably practicable for claimant to present her claim on time. Claimant knew the time limits, had union advice and support, was able to prepare a 10-page grievance, and could have contacted ACAS within the three-month time limit. Claimant's health conditions did not prevent her from commencing ACAS early conciliation on time. Therefore tribunal has no jurisdiction and claim struck out.

Direct Discrimination(disability)struck out

Claims related to period September 2021 to June 2023. Claim presented 19 August 2024, approximately 11 months out of time. Tribunal found no good explanation for delay and that overall prejudice to respondent outweighed prejudice to claimant. Not just and equitable to extend time, therefore claim struck out for lack of jurisdiction.

Indirect Discrimination(disability)struck out

Claims related to period September 2021 to June 2023. Claim presented 19 August 2024, approximately 11 months out of time. Tribunal found no good explanation for delay and that overall prejudice to respondent outweighed prejudice to claimant. Not just and equitable to extend time, therefore claim struck out for lack of jurisdiction.

Indirect Discrimination(sex)struck out

Claims related to period September 2021 to June 2023. Claim presented 19 August 2024, approximately 11 months out of time. Tribunal found no good explanation for delay and that overall prejudice to respondent outweighed prejudice to claimant. Not just and equitable to extend time, therefore claim struck out for lack of jurisdiction.

Indirect Discrimination(race)struck out

Claims related to period September 2021 to June 2023. Claim presented 19 August 2024, approximately 11 months out of time. Tribunal found no good explanation for delay and that overall prejudice to respondent outweighed prejudice to claimant. Not just and equitable to extend time, therefore claim struck out for lack of jurisdiction.

Failure to Make Reasonable Adjustments(disability)struck out

Claims related to period September 2021 to June 2023, alleging failure to implement occupational health recommendations. Claim presented 19 August 2024, approximately 11 months out of time. Tribunal found no good explanation for delay and that overall prejudice to respondent outweighed prejudice to claimant. Not just and equitable to extend time, therefore claim struck out for lack of jurisdiction.

Facts

Claimant was employed by respondent from August 2022 to March 2024, when dismissed following a stage 3 sickness outcome. She had been off sick since June 2023. Claimant alleged disability discrimination, sex and race discrimination, and failure to make reasonable adjustments relating to attendance management procedures between September 2021 and June 2023. She submitted a grievance on 5 March 2024 and waited for the outcome before commencing ACAS early conciliation on 15 July 2024, and presenting her claim on 19 August 2024.

Decision

All claims struck out as time-barred. Unfair dismissal claim struck out because it was reasonably practicable to present on time; claimant knew the time limits, had union support, and her health conditions did not prevent her from contacting ACAS on time. Discrimination claims struck out as not just and equitable to extend time; delay of 11 months was significant, claimant had no good explanation, and prejudice to respondent in defending stale claims from 2021-2023 outweighed prejudice to claimant.

Practical note

Claimants with health conditions who know the time limits and have union support are expected to act within the statutory time limits; waiting for a grievance outcome is not a good reason for delay when the claimant understood the obligation to contact ACAS within three months.

Legal authorities cited

Marley (UK) Ltd v Anderson [1994] IRLR 152Bexley Community Centre (trading as Leisure Link) v Robertson [2003] ILR 434Jones v Secretary of State for Health and Social Care [2024] EAT 2Adedeji v University Hospitals Birmingham NHS Foundation Trust [2021] EWCA Civ 23Cullinane v Balfour Beatty Engineering Services Ltd UKEAT/0537/10Trevelyans (Birmingham) Ltd v Norton [1991] ICR 488Walls Meat Co Ltd v Khan [1972] ICR 52Westward Circuits Ltd v Read [1973] 2 All ER 1013

Statutes

ERA 1996 s.111Limitation Act 1980 s.33EqA 2010 s.140BEqA 2010 s.123ERA 1996 s.207B

Case details

Case number
6008931/2024
Decision date
10 February 2025
Hearing type
strike out
Hearing days
1
Classification
procedural

Respondent

Sector
education
Represented
Yes
Rep type
barrister

Employment details

Service
2 years

Claimant representation

Represented
No