Cases3314702/2021

Claimant v MPK Garages Limited

Outcome

Other

Individual claims

Automatic Unfair Dismissalnot determined

Tribunal determined it had jurisdiction over the claim as it was not reasonably practicable for the claimant to present the claim within the primary time limit and the claim was presented within a reasonable time thereafter (by 30 June 2021).

Discrimination Arising from Disability (s.15)(disability)not determined

Tribunal found it just and equitable to extend time for the disability discrimination claims (including dismissal on 18 December 2020) to 22 August 2021, granting jurisdiction. The substantive merits were not determined at this preliminary hearing.

Failure to Make Reasonable Adjustments(disability)not determined

Tribunal extended time on just and equitable grounds to 22 August 2021 for discrimination claims not part of a continuing act linked to dismissal. Respondent conceded claimant is disabled by dyslexia but disputes knowledge of disability and its effects.

Facts

Mr Polley, who has dyslexia, was dismissed by MPK Garages Limited on 18 December 2020. He filed his claim on 22 August 2021, significantly after the primary three-month time limit expired on 17 March 2021. The preliminary hearing addressed whether the tribunal had jurisdiction to hear his claims of automatic unfair dismissal and disability discrimination given the delay in filing.

Decision

The tribunal found it had jurisdiction over all claims. For automatic unfair dismissal, it was not reasonably practicable to file in time and the claim was filed within a reasonable period. For disability discrimination claims, time was extended on just and equitable grounds to 22 August 2021. The respondent conceded the claimant is disabled due to dyslexia.

Practical note

Tribunals will consider extending time limits for both unfair dismissal (reasonably practicable test) and discrimination claims (just and equitable test) where claimants can show good reasons for delay, particularly where disability may have affected their ability to file on time.

Legal authorities cited

Statutes

Equality Act 2010 s.6

Case details

Case number
3314702/2021
Decision date
23 January 2025
Hearing type
preliminary
Hearing days
1
Classification
contested

Respondent

Sector
retail
Represented
Yes
Rep type
lay rep

Claimant representation

Represented
No