Cases8000624/2023

Claimant v Hamill Homecare Limited

10 January 2025Before Employment Judge D HoeyScotlandon papers

Outcome

Other

Individual claims

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

This preliminary hearing dealt only with an amendment application. The substantive disability discrimination claims under sections 15 and 20 Equality Act 2010 remain to be determined at full hearing scheduled for 8 January 2025. Respondent has conceded claimant's disability status.

Unfair Dismissalwithdrawn

Claimant withdrew the unfair dismissal complaint at case management preliminary hearing. The Note following that hearing confirmed only disability discrimination complaint would proceed.

Unlawful Deduction from Wagesstruck out

Claimant sought to amend claim to add complaint about non-payment of final week's wages in July 2024, nine months after filing. Tribunal refused amendment as: complaint was out of time with no explanation for delay or evidence it was not reasonably practicable to bring in time; it would introduce entirely new complaint requiring different evidence; respondent stated payment withheld pending return of uniform per contract terms and would be paid on return; and claimant could pursue remedy in Sheriff Court.

Facts

Claimant filed disability discrimination claim in November 2023, later withdrawing unfair dismissal complaint. In July 2024, nine months after filing, claimant sought to amend to add claim for non-payment of final week's wages, which respondent said was withheld pending return of uniform as per contract. Claimant's final wage paid 28 September 2023. Claimant provided no explanation for delay in raising wages claim and did not tick relevant boxes on original ET1.

Decision

Tribunal refused amendment application as it would introduce entirely new complaint requiring different evidence, was significantly out of time with no explanation for delay or evidence it was not reasonably practicable to bring in time, and balance of hardship favoured respondent. Claimant retained alternative remedy in Sheriff Court for contractual claim.

Practical note

Amendment applications to add new complaints months after filing will be refused where significantly out of time, no explanation for delay provided, and claimant has alternative remedy available - particularly where proposed claim appears unlikely to succeed on merits.

Legal authorities cited

Sefton MBC v Hincks [2011] ICR 1357Newstar Asset Management v Evershed UKEAT/249/09 [2010] EWCA 870Street v Derbyshire Unemployed Workers Centre [2005] ICR 97British Newspaper Printing v Kelly [1989] IRLR 222Selkent Bus Co v Moore [1996] IRLR 661Abercrombie v Aga Rangemaster Ltd [2014] ICR 204Jesuthasan v Hammersmith [1998] IRLR 372Vaughan v Modality Partnership [2021] IRLR 535Chaudhry v Cerberus [2022] EAT

Statutes

Employment Tribunals (Constitution and Rules of Procedure) Regulations 2013Employment Rights Act 1996 s.23Equality Act 2010 s.20Equality Act 2010 s.15

Case details

Case number
8000624/2023
Decision date
10 January 2025
Hearing type
preliminary
Hearing days
1
Classification
contested

Respondent

Sector
healthcare
Represented
Yes
Rep type
solicitor

Claimant representation

Represented
No