Cases3201939/2023

Claimant v University of East London

13 August 2024Before Employment Judge BrewerLondon Eastremote video

Outcome

Claimant fails

Individual claims

Direct Discrimination(disability)failed

The tribunal found that the claimant did not meet the definition of disability under section 6 of the Equality Act 2010. The claimant asserted he had generalised anxiety disorder, but the medical evidence did not support this diagnosis during the material period (September 2022 to January 2024). The tribunal found the claimant suffered work-related stress/anxiety for approximately 8 months, but this did not have a substantial adverse effect on normal day-to-day activities. The claimant's disability impact statement was not supported by contemporaneous medical evidence. The claims were therefore dismissed as the claimant could not establish disabled status.

Facts

The claimant, a senior lecturer at the University of East London, refused to take on additional course leader duties from September 2022, asserting he had generalised anxiety disorder requiring reasonable adjustments. The respondent persisted with the request, the claimant raised a grievance (not upheld), and disciplinary proceedings commenced in October 2023. The claimant went off sick in October 2023 and resigned in January 2024. This was a preliminary hearing to determine whether the claimant was disabled within the meaning of the Equality Act 2010.

Decision

The tribunal dismissed the disability discrimination claims, finding the claimant did not meet the definition of disability. There was no medical evidence supporting generalised anxiety disorder diagnosis before October 2023. The tribunal found the claimant experienced work-related stress/anxiety for approximately 8 months but found a stark mismatch between his disability impact statement and contemporaneous medical records. The claimant's anxiety did not have a substantial adverse effect on normal day-to-day activities, and he continued to perform his job competently throughout the material period.

Practical note

A claimant's disability impact statement alone is insufficient when contradicted by extensive contemporaneous medical evidence showing no substantial adverse effect on normal day-to-day activities, even where some workplace stress or anxiety is documented.

Legal authorities cited

Goodwin v Patent Office [1999] ICR 302McNicol v Balfour Beatty Rail Maintenance Ltd 2002 ICR 1498J v DLA Piper UK LLP [2010] ICR 1052Boyle v SCA Packaging Ltd 2009 ICR 1056Paterson v Commissioner of Police of the Metropolis 2007 ICR 1522All Answers Ltd v W 2021 IRLR 612Elliott v Dorset County Council EAT 0197/20Wigginton v Cowie t/a Baxter International EAT 0322/09Rugamer v Sony Music Entertainment UK Ltd 2002 ICR 381Herry v Dudley Metropolitan Council 2017 ICR 610Saad v University Hospital Southampton NHS Trust EAT 0184/14Aderemi v London and South Eastern Railway Ltd [2013] ICR 591Chacón Navas v Eurest Colectividades SA 2007 ICR 1

Statutes

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

Case details

Case number
3201939/2023
Decision date
13 August 2024
Hearing type
preliminary
Hearing days
1
Classification
procedural

Respondent

Sector
education
Represented
Yes
Rep type
barrister

Employment details

Role
Senior Lecturer in the School of Health, Sport and Bioscience
Service
12 years

Claimant representation

Represented
No