Cases6004210/2024

Claimant v Wind River UK Ltd

3 December 2024Before Employment Judge CuthbertBristolremote video

Outcome

Claimant fails

Individual claims

Direct Discrimination(disability)dismissed on withdrawal

The tribunal found the claimant had not established he was disabled under s.6 Equality Act 2010. There was no clinical diagnosis of ASD/Asperger's or ADHD, only self-diagnosis. The tribunal found insufficient evidence of substantial adverse effects on normal day-to-day activities arising from any mental impairment. All disability discrimination claims were therefore dismissed.

Discrimination Arising from Disability (s.15)(disability)dismissed on withdrawal

The claim was dismissed because the claimant failed the threshold test: he did not prove he was a disabled person under s.6 of the Equality Act 2010 at the relevant dates. The alleged discriminatory acts occurred between late 2020 and April 2024, but no disability status was established.

Constructive Dismissalnot determined

This claim was listed for full hearing in December 2025 and was not determined at this preliminary hearing. Only the disability status issue was determined.

Whistleblowingnot determined

Whistleblowing detriment and constructive dismissal claims were listed for full hearing in December 2025 and not determined at this preliminary hearing.

Unlawful Deduction from Wagesnot determined

Unlawful deduction from wages claims were listed for full hearing in December 2025 and not determined at this preliminary hearing.

Facts

A 46-year-old Field Applications Engineer worked for Wind River UK Ltd from April 2019 to June 2024. He claimed to have Asperger's/ASD and ADHD, relying on self-diagnosis from 2023 onwards. GP records showed he first sought clinical assessment in June 2023, but no diagnosis had been obtained by the hearing in July 2025. He gave evidence of communication difficulties at work (talking over others, particularly in 2021), lack of empathy, hyper-focus then losing interest, excessive mobile phone use, and untidy handwriting. He had, however, learned to mask some behaviours.

Decision

The tribunal found the claimant was not disabled under s.6 Equality Act 2010. There was no clinical diagnosis, only self-diagnosis insufficient to establish the pleaded impairments of ASD/ADHD. The claimant failed to prove substantial adverse effects on normal day-to-day activities. The communication difficulties at work in 2021 were not substantial (addressed informally, no recurrence), and other alleged effects (mobile phone use, untidy handwriting) were minor or trivial. All disability discrimination claims were dismissed.

Practical note

Self-diagnosis of neurodiverse conditions without clinical assessment is generally insufficient to establish disability, particularly where alleged effects are minor, isolated to a short period, or successfully masked through coping strategies.

Legal authorities cited

Herry v Dudley Metropolitan Council UKEAT/0100/16Mr A Elliot v Dorset County Council UKEAT/0197/20/LACruickshank v Vaw Motorcast Ltd [2002] I.C.R. 729Stedman v Haven Leisure Ltd [2025] EAT 82Sullivan v Bury Street Capital Limited [2021] EWCA Civ 1694McNicol v Balfour Beatty Rail Maintenance Ltd [2002] EWCA Civ 1074Morgan v Staffordshire University [2002] ICR 475Goodwin v Patent Office [1999] ICR 302J v DLA Piper UK LLP [2010] ICR 1052Royal Bank of Scotland plc v Morris EAT 0436/10

Statutes

Equality Act 2010 s.212Equality Act 2010 Sch 1 para 5Equality Act 2010 Sch 1 para 2Equality Act 2010 s.6

Case details

Case number
6004210/2024
Decision date
3 December 2024
Hearing type
preliminary
Hearing days
1
Classification
procedural

Respondent

Sector
technology
Represented
Yes
Rep type
barrister

Employment details

Role
Field Applications Engineer
Service
5 years

Claimant representation

Represented
Yes
Rep type
barrister