Cases8000770/2024

Claimant v GB Land Engineering Limited

27 January 2025Before Employment Judge M SangsterScotlandremote video

Outcome

Claimant fails

Individual claims

Direct Discrimination(religion)struck out

Claim struck out for being out of time. The tribunal found no jurisdiction as the claim was presented 82 days late and it was not just and equitable to extend time. The claimant failed to provide satisfactory explanation for the delay and his ignorance of time limits was unreasonable.

Indirect Discrimination(religion)struck out

Claim struck out for being out of time. The tribunal found no jurisdiction as the claim was presented 82 days late and it was not just and equitable to extend time. The claimant failed to provide satisfactory explanation for the delay.

Victimisationstruck out

Claim struck out for being out of time. The tribunal found no jurisdiction as the claim was presented 82 days late and it was not just and equitable to extend time. The claimant's asserted physical and mental health issues did not create any impediment to presenting the claim earlier.

Facts

The claimant was employed by the respondent from June to December 2023. He believed he was subjected to religious discrimination during August/September to December 2023 and was told his contract would not be renewed, which he attributed to his religion. He contacted Acas before his employment ended, then Citizens Advice in March 2024, and commenced early conciliation on 16 April 2024. He presented his claim on 3 June 2024, 82 days after the primary time limit expired. The claimant attributed the delay to physical pain (lower back and leg pain) and low mood, though he did not seek medical treatment until February 2024 and was not prescribed significant medication until after the claim was filed.

Decision

The tribunal struck out all claims for lack of jurisdiction, finding the claim was presented 82 days out of time and it was not just and equitable to extend time. The tribunal rejected the claimant's explanations: his physical and mental health did not prevent him from claiming earlier, as evidenced by his ability to engage with Citizens Advice, Acas and apply for benefits; and his ignorance of time limits was unreasonable given his contact with advice agencies and failure to make basic enquiries.

Practical note

Self-represented claimants cannot rely on ignorance of time limits where they have contacted advice agencies and failed to make reasonable enquiries, and general ill-health without medical evidence of incapacity will not establish just and equitable grounds for extension.

Legal authorities cited

Keeble v British Coal Corporation [1997] IRLR 336Robertson v Bexley Community Centre [2003] IRLR 434London Borough of Southwark v Afolabi [2003] IRLR 220Abertawe Bro Morgannwg University Local Health Board v Morgan [2018] EWCA Civ 640Adedeji v University Hospitals Birmingham NHS Foundation Trust [2021] EWCA Civ 23Dalgleish v McLaren Packaging 4109146/2001

Statutes

Limitation Act 1980 s.33Equality Act 2010 s.123

Case details

Case number
8000770/2024
Decision date
27 January 2025
Hearing type
preliminary
Hearing days
1
Classification
contested

Respondent

Sector
construction
Represented
Yes
Rep type
barrister

Employment details

Service
6 months

Claimant representation

Represented
No