Cases1806600/2023

Claimant v GXO Logistics

22 January 2025Before Regional Employment Judge S DaviesLeedson papers

Outcome

Claimant fails

Individual claims

Unfair Dismissalstruck out

The claim was struck out under Rule 38 because the claimant failed to actively pursue the claim and failed to comply with multiple tribunal orders regarding disclosure, witness statements, and providing medical evidence about fitness to participate. Despite repeated extensions and warnings, the claimant did not progress the case for over a year, and there was no indication when he would be able to do so.

Facts

The claimant brought an unfair dismissal claim apparently following dismissal due to long-term ill health absence. The claim was filed in October 2023 with a hearing initially scheduled for March 2024. The claimant repeatedly asked for the proceedings to be suspended due to ill health (anxiety, knee problems, depression) and homelessness. Despite multiple postponements and orders from three different judges, the claimant failed to comply with case management orders or provide adequate medical evidence about his fitness to participate in proceedings. Over a year after filing, the claim had made no progress.

Decision

Employment Judge Davies struck out the claim under Rule 38 for both non-pursuit and failure to comply with tribunal orders. The judge found inordinate delay creating substantial risk that a fair hearing was no longer possible, with no indication when the claimant would be able to proceed. The judge considered the claimant's ill health but concluded that striking out was proportionate given the prejudice to the respondent, the need to deliver justice within a reasonable time, and the lack of any alternative remedy.

Practical note

Even where a claimant has genuine health difficulties, tribunals will strike out claims where there is prolonged non-compliance with orders, no indication when proceedings can progress, and no lesser remedy is appropriate—claimants cannot simply file claims and then unilaterally suspend them indefinitely.

Legal authorities cited

Hendricks v Metropolitan Police Commissioner [2003] ICR 530Blockbuster Entertainment Ltd v James [2006] IRLR 630Harris v Academies Enterprise Trust [2015] ICR 617Weir Valves and Controls (UK) Ltd v Armitage [2001] ICR 371

Statutes

Employment Tribunal Rule 38

Case details

Case number
1806600/2023
Decision date
22 January 2025
Hearing type
strike out
Hearing days
Classification
procedural

Respondent

Sector
logistics
Represented
Yes
Rep type
solicitor

Claimant representation

Represented
No