Cases6001680/2023

Claimant v Environment Agency

24 June 2024Before Employment Judge SmailExeterin person

Outcome

Claimant fails

Individual claims

Discrimination Arising from Disability (s.15)(disability)struck out

The claim was struck out under Rule 37(1)(a) as having no reasonable prospects of success because the same complaints were already litigated and dismissed as out of time in case no. 1402514/2021. The tribunal found the bringing of the present claim was res judicata and tantamount to an abuse of process under Henderson principles.

Whistleblowingstruck out

The tribunal found this claim should have been raised in the earlier proceedings (1402514/2021) if it was to be raised at all. The claim was struck out as having no reasonable prospects of success and constituting an abuse of process.

Facts

The claimant was an Environment Officer who developed psychiatric illness following threats from a waste disposal contractor he had prosecuted. He left employment on 30 November 2016 under a Compromise Agreement receiving £51,914, having been advised by a barrister. He sought decisions on occupational injury allowance and ill health early retirement from active pension membership. He brought an earlier tribunal claim (1402514/2021) which was dismissed as out of time in April 2023. He then brought the present claim in August 2023 seeking the same remedies.

Decision

The tribunal struck out the claim under Rule 37(1)(a) as having no reasonable prospects of success. The judge found the matters had already been litigated and dismissed as out of time in the earlier case. Applying res judicata principles and Henderson abuse of process, the bringing of the present claim was tantamount to abuse. The whistleblowing claim should also have been raised in the earlier proceedings.

Practical note

A claimant cannot circumvent a time-bar dismissal by bringing a second claim based on the same facts and events, even if framed slightly differently or relying on later correspondence - this will be struck out as res judicata and abuse of process under Henderson principles.

Legal authorities cited

Johnson v Gore Wood & Co [2002] 2 AC 1Agbenowossi-Koffi v Donvand Ltd [2014] EWCA Civ 855Henderson v Henderson [1843] 3 Hare 100Virgin Atlantic Airways Ltd v Zodiac Seats UK Ltd [2014] AC 160

Statutes

Local Government Pension Scheme Regulations (Regulation 74)Local Government (Discretionary Payments) (Injury Allowances) Regulations 2011Equality Act 2010 s.123

Case details

Case number
6001680/2023
Decision date
24 June 2024
Hearing type
strike out
Hearing days
1
Classification
procedural

Respondent

Name
Environment Agency
Sector
regulator
Represented
Yes
Rep type
barrister

Employment details

Role
Environment Officer
Service
12 years

Claimant representation

Represented
No