Cases6015422/2024

Claimant v FearFree

5 December 2024Before Employment Judge J BaxBristolon papers

Outcome

Claimant fails

Individual claims

Constructive Dismissalstruck out

The claim was struck out because the claimant did not have the required two years' continuous service to bring an unfair dismissal claim under s.108 of the Employment Rights Act 1996, and the case did not fall within any of the statutory exceptions to this requirement.

Direct Discrimination(disability)not determined

The tribunal confirmed that the striking out of the unfair dismissal claim does not affect the claimant's continuing discrimination claim under s.39(2) of the Equality Act 2010, which has no minimum service requirement and remains to be determined.

Facts

The claimant resigned and alleged constructive dismissal linked to disability discrimination. Her unfair dismissal claim was struck out on 5 December 2024 because she lacked two years' continuous service required under s.108 ERA 1996. She applied for reconsideration on 15 December 2024, arguing that discrimination cases should not be subject to the two-year rule and that her dismissal was discriminatory under the Equality Act 2010.

Decision

The tribunal refused the reconsideration application because there was no reasonable prospect of varying or revoking the original judgment. The two-year service requirement for unfair dismissal claims applies regardless of whether discrimination is alleged. The claimant's discrimination claim under s.39(2) Equality Act 2010 remains unaffected and can proceed without a minimum service requirement.

Practical note

A claimant cannot circumvent the two-year qualifying period for unfair dismissal by linking the dismissal to discrimination, but discrimination claims themselves have no service requirement and can proceed independently.

Legal authorities cited

Archibald v Fife Council [2004] UKHL 32London Borough of Waltham Forest v Omilaju [2004] EWCA Civ 1493Trimble v Supertravel Ltd [1982] ICR 440Fforde v Black EAT 68/80Williams v Ferrosan Ltd [2004] IRLR 607Newcastle Upon Tyne City Council v Marsden [2010] IRLR 743Outasight VB Ltd v Brown [2015] ICR D11Nottinghamshire County Council v Meikle [2004] EWCA Civ 859

Statutes

EqA 2010 s.39(2)ERA 1996 s.108

Case details

Case number
6015422/2024
Decision date
5 December 2024
Hearing type
reconsideration
Hearing days
Classification
procedural

Respondent

Sector
other
Represented
No

Claimant representation

Represented
No