Cases2201912/2022

Claimant v Moorfields Eye Hospital NHS Foundation Trust

9 July 2024Before Employment Judge AkhtarLondon Centralon papers

Outcome

Claimant fails

Individual claims

Direct Discrimination(age)failed

The claim related to the requirement to use contractual sick pay when shielding during COVID-19. The Tribunal found the claim fundamentally misconceived as the claimant had no entitlement to shielding pay during periods when the shielding programme was paused.

Direct Discrimination(race)failed

The claim related to the requirement to use contractual sick pay when shielding during COVID-19. The Tribunal found the claim fundamentally misconceived as the claimant had no entitlement to shielding pay during periods when the shielding programme was paused.

Direct Discrimination(disability)failed

The claim related to the requirement to use contractual sick pay when shielding during COVID-19. The Tribunal found the claim fundamentally misconceived as the claimant had no entitlement to shielding pay during periods when the shielding programme was paused.

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

The claim related to the requirement to use contractual sick pay when shielding during COVID-19. The Tribunal found the claim fundamentally misconceived as the claimant had no entitlement to shielding pay during periods when the shielding programme was paused.

Unlawful Deduction from Wagesfailed

The claim related to the requirement to use contractual sick pay when shielding during August 2020 to April 2022 (except March-April 2021). The Tribunal found the claim fundamentally misconceived and that the claimant had an unjustified sense of grievance as she had no entitlement to shielding pay during these periods.

Facts

The claimant pursued claims of age, race, and disability discrimination, discrimination arising from disability, and unauthorised deduction of wages after being required to use contractual sick pay while shielding during COVID-19 from August 2020 to April 2022. The claims were dismissed in July 2024 as fundamentally misconceived. The respondent then applied for costs of up to £20,000, arguing the claimant had acted unreasonably and pursued claims with no reasonable prospects of success despite a costs warning in February 2023.

Decision

The Tribunal found that the threshold for awarding costs was met under Rule 74(2)(a) and (b) - the claimant had acted unreasonably and pursued claims with no reasonable prospect of success. However, the Tribunal exercised its discretion not to award costs due to the claimant's inability to pay. The claimant was in receipt of Universal Credit of approximately £1,556 per month with no savings, mounting debts, and no evidence her financial position would improve.

Practical note

Even where the threshold for a costs order is clearly met due to unreasonable conduct and lack of merit, tribunals retain discretion to refuse costs applications where the paying party has no realistic ability to pay and enforcement would serve no practical compensatory purpose.

Legal authorities cited

Yerrakalva v Barnsley Metropolitan Borough Council [2012] ICR 420Jilley v Birmingham and Solihull Mental Health NHS Trust UKEAT/0584/06AQ Ltd v Holden [2012] UKEAT/0021/12/CEADyer v Secretary of State for Employment [1983] UKEAT 183/83Sahota v Dudley Metropolitan Borough Council EAT 0821/03Mrs S Solomon v University of Hertfordshire and Hammond UKEAT/0258/18/DAKopel v Safeway Stores [2003] IRLR 753D'Silva v NATFHE [2009] UKEAT 0126/09Salinas v Bear Stearns International Holdings Inc [2005] ICR 1117, EATSud v Ealing London Borough Council 2013 ICR D39, CAChadburn v Doncaster & Bassetlaw Hospital NHS Foundation Trust UKEAT/0259/14/LA

Statutes

Employment Tribunals (Constitution and Rules of Procedure) Regulations 2013 Rule 76Employment Tribunal Procedure Rules 2024 Rule 76Employment Tribunal Procedure Rules 2024 Rule 82Employment Tribunal Procedure Rules 2024 Rule 74

Case details

Case number
2201912/2022
Decision date
9 July 2024
Hearing type
costs
Hearing days
Classification
procedural

Respondent

Sector
healthcare
Represented
Yes
Rep type
solicitor

Claimant representation

Represented
No