Cases1805096/2023

Claimant v Royal Mail Group Limited

12 July 2024Before Employment Judge AyreLeedsin person

Outcome

Claimant fails

Individual claims

Discrimination Arising from Disability (s.15)(disability)failed

The tribunal found that the unfavourable treatment (threats to cancel overtime and comments about needing to be ready for any job) were not caused by the claimant's inability to do bag tipping duties, which was the 'something arising from disability' relied upon. Instead, the treatment was caused by the claimant's refusal to work on the wing of the Caljan machine. The claim failed at the causation stage as the pleaded 'something arising' did not cause the unfavourable treatment.

Direct Discrimination(race)withdrawn

The claimant withdrew his race discrimination complaint at a preliminary hearing before Employment Judge Cox on 15 February 2024, and it was dismissed.

Direct Discrimination(religion)withdrawn

The claimant withdrew his religion or belief discrimination complaint at a preliminary hearing before Employment Judge Cox on 15 February 2024, and it was dismissed.

Facts

The claimant, a part-time postal processor with chronic back pain, was working overtime on 1 June 2023 in the oversize sorting area. After complaining of a headache and refusing to work on the wing of the Caljan machine, he was threatened with cancellation of his overtime by Mr Lloyd. He was ultimately moved to bag tipping duties where he completed his shift. Mr Joshi told him he must be ready to do any job when working overtime. The claimant alleged these were acts of discrimination arising from his inability to do bag tipping duties.

Decision

The tribunal found that while the comments by Mr Lloyd and Mr Joshi constituted unfavourable treatment, they were not caused by the claimant's inability to do bag tipping (the pleaded 'something arising from disability'). Instead, they were caused by the claimant's refusal to work on the Caljan machine wing. The claim failed at the causation stage. Even if established, the tribunal found the respondent's actions would have been proportionate given the need to maintain service obligations and the limited discriminatory effect.

Practical note

In section 15 claims, tribunals are bound by the specific 'something arising from disability' pleaded at case management — even where there is an obvious causal link between the treatment and disability via a different route, the claim will fail if causation is not established for the pleaded 'something arising'.

Legal authorities cited

Vento v Chief Constable of West Yorkshire Police [2003] ICR 318Secretary of State for Justice v Dunn EAT 0234/16Pnaiser v NHS England [2016] IRLR 170Land Registry v Houghton UKEAT/0149/14

Statutes

Equality Act 2010 s.15

Case details

Case number
1805096/2023
Decision date
12 July 2024
Hearing type
full merits
Hearing days
1
Classification
contested

Respondent

Sector
logistics
Represented
Yes
Rep type
solicitor

Employment details

Role
Postal Processor
Service
2 years

Claimant representation

Represented
No