Cases1405660/2023

Claimant v Roke Manor Research Limited

29 January 2025Before Employment Judge GraySouthampton

Outcome

Claimant fails

Individual claims

Discrimination Arising from Disability (s.15)(disability)failed

The tribunal found the claimant was disabled by reason of PTSD and co-morbid depression/anxiety, but not Asperger's Syndrome. The respondent lacked knowledge of the substantial disadvantage. The dismissal was because of failure to meet technical competency standards, not because of anything arising from disability. The claimant maintained throughout that his technical ability was not compromised by his disability.

Failure to Make Reasonable Adjustments(disability)failed

The tribunal found the respondent knew the claimant had a long-term mental health condition and provided the requested adjustment (flexible working hours). However, the claimant never informed the respondent that he suffered from intrusion or was unable to concentrate fully. The respondent did not have the requisite knowledge of the disability or the substantial disadvantage claimed.

Facts

The claimant was employed as a Sales Solution Architect from November 2022, subject to a six-month probation. He disclosed a long-term mental health condition to Occupational Health and was granted flexible working hours (4 days per week). He worked on three projects during probation. Feedback from colleagues on all three projects raised concerns about his technical ability, software delivery capability, time management, and interpersonal skills. On 25 May 2023, following a probation review, he was dismissed for failing to meet the required technical standards. At the review meeting, he disclosed Asperger's Syndrome for the first time. He appealed, alleging disability discrimination.

Decision

The tribunal accepted the claimant was disabled by PTSD, depression and anxiety, but not Asperger's Syndrome due to insufficient evidence. Both discrimination claims failed. The section 15 claim failed because: (1) the respondent lacked knowledge of substantial disadvantage; (2) the dismissal was because of insufficient technical competency, not anything arising from disability; and (3) the claimant himself consistently maintained his technical ability was not compromised by disability. The reasonable adjustments claim failed because the respondent had no knowledge that the claimant suffered intrusion or concentration difficulties.

Practical note

An employer cannot be liable for failure to make reasonable adjustments or discrimination arising from disability where the employee has not disclosed the nature and impact of their condition, and the employer has already implemented the only adjustment requested (flexible working).

Legal authorities cited

Vento v Chief Constable of West Yorkshire Police [2003] ICR 318Pnaiser v NHS England [2016] IRLR 170Madarassy v Nomura International Plc [2007] ICR 867City of York Council v Grosset [2018] IRLR 746Igen v Wong [2005] ICR 931Environment Agency v Rowan [2008] ICR 218A Ltd v Z [2019] IRLR 952Gallop v Newport City Council [2014] IRLR 211SCA Packaging Ltd v Boyle [2009] UKHL 37Hewett v Motorola Ltd 2004 IRLR 545Anwar v Tower Hamlets College UKEAT/0091/1Basildon and Thurrock NHS Foundation Trust v Weerasinghe [2016] ICR 305Seldon v Clarkson Wright and Jakes [2012] IRLR 590Bilka-Kaufhaus GmbH v Weber Von Harz (Case 170/84) [1984] IRLR 317Hardys & Hansons plc v Lax [2005] IRLR 726

Statutes

Equality Act 2010 s.15Equality Act 2010 s.6Equality Act 2010 s.20Equality Act 2010 s.21Equality Act 2010 s.123Equality Act 2010 s.136Equality Act 2010 Sch.1 para.2(1)Equality Act 2010 Sch.1 para.5(1)Equality Act 2010 Sch.8 para.20(1)

Case details

Case number
1405660/2023
Decision date
29 January 2025
Hearing type
full merits
Hearing days
3
Classification
contested

Respondent

Sector
technology
Represented
Yes
Rep type
barrister

Employment details

Role
Sales Solution Architect / Grade 6 Engineer
Service
6 months

Claimant representation

Represented
No