Cases3300074/2024

Claimant v London Brunel International College

7 February 2025Before Employment Judge Andrew Clarke KCWatfordin person

Outcome

Other

Individual claims

Constructive Dismissalnot determined

This is a preliminary hearing on disability status and time limits only. The substantive claim of constructive unfair dismissal has not yet been determined and will be heard at final hearing.

Direct Discrimination(disability)not determined

Tribunal found claimant was not disabled by reason of anxiety and depression at relevant times, though respondent had already conceded disability status for adenomyosis. Direct disability discrimination claims based on anxiety/depression will fail but claims based on adenomyosis remain live for final hearing.

Indirect Discrimination(disability)not determined

As with direct discrimination, claims based on anxiety/depression disability will not succeed following this preliminary finding, but claims based on adenomyosis disability remain for determination at final hearing.

Failure to Make Reasonable Adjustments(disability)not determined

Claimant found not to be disabled by reason of anxiety and depression, but respondent has conceded disability status for adenomyosis. Reasonable adjustments claims can proceed to final hearing on the basis of adenomyosis disability.

Indirect Discrimination(sex)not determined

This claim was not addressed at the preliminary hearing which focused on disability status and time limits. The sex discrimination claim remains to be determined at final hearing.

Victimisationnot determined

Victimisation claim not addressed at this preliminary hearing. Will be determined at final hearing along with other substantive claims.

Harassment(disability)not determined

Disability-related harassment complaints from late 2022/early 2023 were subject to time limit arguments, but tribunal deferred determination to final hearing. Harassment claims based on anxiety/depression disability are undermined by the finding that claimant was not disabled by that condition, but harassment claims based on adenomyosis remain live.

Facts

Claimant was employed by respondent from December 2020 until resigning in December 2023. Claimant brought multiple claims including constructive dismissal and various discrimination claims based on two alleged disabilities: adenomyosis (which respondent conceded was a disability) and anxiety/depression. Claimant relied on evidence of mental ill health in 2016 and again in 2022/2023, including referrals for CBT and counselling, medical records noting reactive depression and adjustment disorder, and a prescription for Sertraline from January 2024.

Decision

Tribunal found claimant was not disabled by reason of anxiety and depression at relevant times under s.6 Equality Act 2010. Medical evidence pointed to adverse reaction to life events rather than clinical illness, and claimant failed to prove the long-term condition or substantial adverse effects on day-to-day activities. Tribunal deferred determination of time limit issues regarding disability-related harassment complaints to final hearing, finding the claims too complex and factually interlinked to determine jurisdiction at preliminary stage.

Practical note

Mental health disability claims require clear medical evidence distinguishing clinical illness from situational reactions to adverse events, and claimants must provide specific evidence of substantial effects on normal day-to-day activities at the relevant time, not just current effects.

Legal authorities cited

J v DLA Piper UK LLP [2010] ICR 1052Goodwin v Patent Office [1999] ICR 302Mutombo-Mpania v Angard Staffing Solutions Ltd UKEATS/0002/18Chief Constable of Norfolk v Coffey [2019] EWCA Civ 1061Richmond Adult Community College v McDougall [2008] IRLR 227All Answers Ltd v W [2021] IRLR 621Boyle v SCA Packaging Ltd [2009] IRLR 746SCA Packaging Ltd v Boyle [2009] ICR 1056RBS v Morris UKEAT/0436/10/MAALyfar v Brighton and Sussex University Hospitals Trust [2006] EWCA Civ 1548Aziz v FDA [2010] EWCA Civ 304Chief Constable of Lincolnshire Police v Caston [2010] IRLR 327British Coal Corpn v Keeble [1997] IRLR 336Hendricks v Metropolitan Police Commissioner [2003] ICR 530Morgan v Staffordshire University [2002] IRLR 190

Statutes

Equality Act 2010 s.6Equality Act 2010 s.212(2)Equality Act 2010 Sch 1 Part 1Equality Act 2010 Sch 1 para 5Equality Act 2010 s.123

Case details

Case number
3300074/2024
Decision date
7 February 2025
Hearing type
preliminary
Hearing days
1
Classification
contested

Respondent

Sector
education
Represented
Yes
Rep type
barrister

Employment details

Service
3 years

Claimant representation

Represented
No