Cases2304938/2022

Claimant v Cathay Investments Ltd

3 July 2024Before Employment Judge HindmarchLondon Southremote video

Outcome

Other

Individual claims

Direct Discrimination(race)withdrawn

At a case management preliminary hearing on 29 June 2023, the claimant withdrew the race discrimination claim. The tribunal did not determine this claim on the merits.

Direct Discrimination(disability)not determined

This was a preliminary hearing only to determine disability status and strike out/deposit order applications. The tribunal found the claimant was disabled by reason of schizophrenia, anxiety and stress. The merits of the discrimination claim remain to be determined at the final hearing.

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

The tribunal determined disability status at this preliminary hearing only. Whether the claimant was dismissed because of something arising in consequence of his disability remains to be determined at the final hearing.

Failure to Make Reasonable Adjustments(disability)not determined

Disability status was determined at this preliminary hearing. Whether the respondent failed to make reasonable adjustments for the claimant's schizophrenia, anxiety and stress remains to be determined at the final hearing.

Facts

The claimant was employed as a Legal Executive by the respondent for five weeks from 14 November to 19 December 2022. He informed the respondent he had a long-term mental health condition requiring regular medical appointments and medication causing drowsiness. He was dismissed during his probationary period. The claimant initially brought claims of race and disability discrimination but withdrew the race claim. The respondent challenged whether the claimant was disabled and applied to strike out or order a deposit on the remaining disability discrimination claims.

Decision

The tribunal found the claimant was disabled by reason of schizophrenia, anxiety and stress at the relevant time, relying on medical evidence showing long-term mental health difficulties since 2009 with substantial effects on day-to-day activities. The tribunal refused the respondent's strike out application, finding factual disputes about the respondent's knowledge of disability and reason for dismissal that must be determined at a full merits hearing. The deposit order and restricted reporting order applications were also refused.

Practical note

Disability status can be established even with limited medical evidence where there is clear evidence of substantial long-term effects on day-to-day activities, and discrimination claims should not be struck out where there are core factual disputes turning on credibility that require oral evidence at a full hearing.

Legal authorities cited

Anyanwu v South Bank Student Union [2001] ICR 391Cruickshank v VAW Motorcast Ltd (2002) LER 727Boyle v SCA Packing Ltd (2009) ICR1056Ezsias v North Glamorgan NHS Trust [2007] EWCA Civ 330Balls v Downham Market High School & College UKEAT/0343/10Cox v Adecco [2021] 4 WLUK 11Van Rensburg v Royal Borough of Kingston-Upon-Thames UKEAT/0096/07British Broadcasting Corporation v Roden (2015) IRLR 627Fallows v News Group Newspaper Ltd UK EAT/0075/16Goodwin v Patent Office [1999] ICR 302

Statutes

Equality Act 2010 s.6

Case details

Case number
2304938/2022
Decision date
3 July 2024
Hearing type
preliminary
Hearing days
1
Classification
procedural

Respondent

Sector
financial services
Represented
Yes
Rep type
barrister

Employment details

Role
Legal Executive
Service
1 months

Claimant representation

Represented
Yes
Rep type
barrister