Cases1401381/2024

Claimant v IQ Healthcare Limited

11 November 2024Before Employment Judge Mr. M. SalterSouthamptonin person

Outcome

Other

Individual claims

Unfair Dismissalnot determined

This was a procedural hearing concerning the claimant's application for anonymity under Rule 50. The tribunal heard the respondent's strike-out application but rejected it. The substantive unfair dismissal claim remains to be determined at a full merits hearing.

Whistleblowingnot determined

The claimant identified himself as a whistleblower and brought claims for whistleblowing detriments and dismissal. An interim relief application failed before EJ Roper in January 2024. The substantive whistleblowing claims have not yet been heard.

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

The claimant brings section 15 Equality Act claims concerning his inability to make the same number of calls as colleagues and his slower working pace arising from his cerebral palsy. The respondent accepts the claimant was disabled and knew of his disability. The substantive claim is yet to be heard.

Failure to Make Reasonable Adjustments(disability)not determined

The claimant alleges failures to adjust call-answering targets, training completion timescales, and the failure to provide a height-adjustable desk suitable for his wheelchair and specialist chair. The respondent accepted the claimant's disability. The substantive claim is yet to be heard.

Victimisationnot determined

A victimisation claim is pleaded but not detailed in this judgment. It is noted that the disability is irrelevant to this claim and it remains to be determined at a full merits hearing.

Facts

The claimant, who has cerebral palsy, brought claims against his former employer for unfair dismissal, whistleblowing, and disability discrimination. He applied for anonymity under Rule 50, arguing that publication of his name alongside details of his disability would breach his Article 8 privacy rights, harm his employment prospects, and exacerbate his anxiety. An interim relief hearing in January 2024 was unsuccessful and published under his full name. He initially sought partial anonymity (initials only), later expanding his application to full anonymity based on medical evidence concerning his anxiety condition.

Decision

The tribunal refused the claimant's application for anonymity. Employment Judge Salter held that the claimant had not provided clear and cogent evidence that harm to his privacy rights was sufficient to justify derogation from the fundamental principle of open justice. The judge found that the substantive claims would require only limited consideration of the claimant's medical condition, the claimant had chosen to initiate proceedings and had been represented throughout without earlier application for anonymity, and the medical evidence did not sufficiently support the need for restriction.

Practical note

Applications for anonymity in disability discrimination cases require clear and cogent evidence of harm that outweighs the fundamental principle of open justice; the mere fact that a claimant has a disability, even if it will be discussed in proceedings, is insufficient without evidence of specific harm arising from publication of the claimant's name.

Legal authorities cited

BBC v Roden [2015] IRLR 630Fallows v News Group Newspapers [2016] ICR 801F v G UKEAT/0042/11R v Legal Aid Board, Ex parte Kaim Todner [1999] QB 966Re Guardian News and Media Ltd [2010] UKSC 1In re S (A Child) [2004] 3 WLR 1129R v Sussex Justices, ex parte McCarthy [1924] KB 256

Statutes

Human Rights Act 1998Rule 50 Employment Tribunal Rules 2013Sections 20 and 21 Equality Act 2010Section 15 Equality Act 2010Article 10 ECHRArticle 8 ECHR

Case details

Case number
1401381/2024
Decision date
11 November 2024
Hearing type
preliminary
Hearing days
1
Classification
procedural

Respondent

Sector
healthcare
Represented
Yes
Rep type
solicitor

Claimant representation

Represented
Yes
Rep type
barrister