Cases2410176/2022

Claimant v HM Revenue & Customs

24 January 2025Before Employment Judge ShotterLiverpoolin person

Outcome

Claimant fails

Individual claims

Harassment(disability)withdrawn

Claims under allegations 4.1.1, 4.1.2 and 4.1.3 were withdrawn by the claimant during the hearing.

Victimisation(disability)withdrawn

Claims under allegations 4.1.1, 4.1.2 and 4.1.3 were withdrawn by the claimant during the hearing.

Harassment(disability)struck out

Claims in allegations 4.1.4, 4.1.5, 4.1.6, 4.1.7, 4.1.8, 4.1.9, 5.2.1, 5.2.2, 5.2.3 and 5.2.4 were out of time (last act 18 July 2022, claim filed 21 December 2022). Tribunal found it was not just and equitable to extend time and dismissed for lack of jurisdiction.

Victimisation(disability)struck out

Claims in allegations 4.1.4, 4.1.5, 4.1.6, 4.1.7, 4.1.8, 4.1.9, 5.2.1, 5.2.2, 5.2.3 and 5.2.4 were out of time (last act 18 July 2022, claim filed 21 December 2022). Tribunal found it was not just and equitable to extend time and dismissed for lack of jurisdiction.

Harassment(disability)failed

In the alternative, for allegations 4.1.4, 4.1.6, 4.1.7, 4.1.8, 4.1.9, 5.2.2, 5.2.3 and 5.2.4, the tribunal found the respondent's conduct did not have the proscribed effect under section 26 of the Equality Act 2010.

Victimisation(disability)failed

In the alternative, for allegations 4.1.4, 4.1.6, 4.1.7, 4.1.8, 4.1.9, 5.2.2, 5.2.3 and 5.2.4, the tribunal found the respondent's conduct did not have the proscribed effect under section 27 of the Equality Act 2010.

Harassment(disability)failed

For allegations 4.1.10, 4.1.11, 4.1.12, 4.1.13, 5.2.5 and 5.2.6, the tribunal found the respondent's conduct did not have the proscribed effect under section 26 of the Equality Act 2010.

Victimisation(disability)failed

For allegations 4.1.10, 4.1.11, 4.1.12, 4.1.13, 5.2.5 and 5.2.6, the tribunal found the respondent's conduct did not have the proscribed effect under section 27 of the Equality Act 2010.

Failure to Make Reasonable Adjustments(disability)failed

The tribunal found that the respondent was not in breach of its duty to make reasonable adjustments under sections 20-21 of the Equality Act 2010 and dismissed the claim.

Facts

The claimant, a disabled employee of HMRC, brought multiple claims of disability discrimination including harassment, victimisation and failure to make reasonable adjustments. The claimant withdrew three initial allegations. The majority of the remaining claims related to events before 18 July 2022 but the claim was not filed until 21 December 2022 following ACAS early conciliation. The claimant represented himself at a six-day full merits hearing.

Decision

The tribunal dismissed all claims. Most claims were struck out as out of time, with the tribunal finding it was not just and equitable to extend time. For the remaining in-time claims and as an alternative for out-of-time claims, the tribunal found the respondent's conduct did not have the proscribed effect under the Equality Act 2010 for harassment and victimisation, and found no breach of the duty to make reasonable adjustments.

Practical note

A self-represented claimant bringing disability discrimination claims against HMRC failed on all grounds due to a combination of time-bar issues and the tribunal finding the conduct complained of did not meet the legal thresholds for harassment, victimisation or failure to make reasonable adjustments.

Legal authorities cited

Statutes

Equality Act 2010 s.20Equality Act 2010 s.27Equality Act 2010 s.21Equality Act 2010 s.26

Case details

Case number
2410176/2022
Decision date
24 January 2025
Hearing type
full merits
Hearing days
6
Classification
contested

Respondent

Sector
central government
Represented
Yes
Rep type
barrister

Claimant representation

Represented
No