Cases2217985/2024

Claimant v Kensington Park School Ltd

5 February 2025Before Employment Judge Mr J S BurnsLondon Centralremote video

Outcome

Claimant fails

Individual claims

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

The tribunal found the claimant failed to prove he was disabled at the relevant time. He did not prove he had the impairments of anxiety and depression, only work-related stress. He failed to prove his condition was likely to last at least 12 months. He failed to prove his mental health problems had a substantial adverse effect on his ability to do day-to-day activities. No medical evidence of diagnosis was provided despite orders for disclosure.

Harassment(disability)struck out

Struck out because the claimant failed to establish he was disabled at the relevant time, which is a prerequisite for disability-related harassment claims under the Equality Act 2010.

Facts

The claimant was a 71-year-old headmaster dismissed in March 2024 after a disciplinary process that began in September 2023. He claimed to suffer from anxiety, depression and stress as a result. He had three sick notes for 'stress at work' covering January to March 2024 but no GP records or formal diagnosis. He continued as Vice-Captain then Captain of his golf club, maintained his golf handicap, took two holidays to Spain, and remained Chair of Governors at another school throughout the relevant period.

Decision

The tribunal struck out the disability discrimination and harassment claims because the claimant failed to prove he was disabled at the relevant time. He only proved work-related stress, not anxiety and depression. There was no medical evidence of diagnosis, no proof the condition would last 12 months, and no proof of substantial adverse effect on day-to-day activities given his active involvement in golf club leadership and school governance.

Practical note

Claimants alleging mental health disability must provide credible medical evidence of diagnosis and substantial impact on daily activities; self-diagnosis and continuation of demanding voluntary roles will fatally undermine such claims.

Legal authorities cited

Royal Bank of Scotland plc v Morris UKEAT_0436_10J v DLA Piper UK LLP UKEAT0263/09/RNMorgan v Staffordshire University [2002] IRLR 190

Statutes

Equality Act 2010 Sch 1 para 2Equality Act 2010 Sch 1 para 5(1) and (2)Equality Act 2010 s.6

Case details

Case number
2217985/2024
Decision date
5 February 2025
Hearing type
preliminary
Hearing days
1
Classification
contested

Respondent

Sector
education
Represented
Yes
Rep type
barrister

Employment details

Role
headmaster

Claimant representation

Represented
Yes
Rep type
barrister