Cases6001223/2023

Claimant v Jet2holidays Limited

18 June 2024Before Employment Judge AyreNorth Eastremote video

Outcome

Claimant fails

Individual claims

Failure to Make Reasonable Adjustments(disability)failed

The tribunal found that the claimant did not discharge the burden of proving she was at substantial disadvantage from lacking two compatible monitors, as she worked successfully with laptop and one monitor for weeks and repeatedly assured management she needed nothing further. In relation to assistance setting up equipment, the respondent had no knowledge of this disadvantage until 20 April 2023, and provided the adjustment (engineer visit) on 12 May 2023 — within 3 weeks. This was not an unreasonable timeframe given limited field engineer resources and ongoing projects. The respondent took considerable steps to support the claimant and made reasonable enquiries about adjustments throughout.

Facts

The claimant, a Travel Advisor registered blind due to visual impairment, claimed the respondent failed to make reasonable adjustments by not providing a desktop PC, two compatible monitors, and engineer assistance to set up equipment at home. She was provided with a laptop and one monitor on starting employment in January 2023. Occupational Health recommended a second monitor in February 2023, which was delivered but the claimant could not connect it herself. The respondent tried remote troubleshooting for several weeks. On 20 April the claimant requested in-person technical assistance. An engineer visited on 12 May and successfully set up two monitors, and a desktop PC was installed on 23 May. Throughout, the claimant repeatedly assured management she had the equipment she needed and did not raise issues with the original setup until after the Occupational Health assessment.

Decision

The tribunal dismissed the claim. It found the claimant did not prove substantial disadvantage from lacking two identical monitors, as she worked successfully with the original setup and repeatedly confirmed she needed nothing further. Regarding engineer assistance, the respondent only had knowledge of this need from 20 April 2023 and provided the adjustment on 12 May — within a reasonable 3-week period given limited resources. The respondent made reasonable enquiries about adjustments and responded positively when issues were raised.

Practical note

Employers must have actual or constructive knowledge of the specific substantial disadvantage before the duty to make reasonable adjustments arises, and may reasonably rely on a disabled employee's assurances that no adjustments are needed when they have made appropriate enquiries.

Legal authorities cited

Abertawe Bro Morgannwg University Local Health Board v Morgan [2018] ICR 1194Tarbuck v Sainsbury's Supermarkets Ltd [2006] IRLR 644Newham Sixth Form College v Sanders [2014] EWCA Civ 734Royal Bank of Scotland v Ashton [2011] ICR 632Environment Agency v Rowan [2008] ICR 218Wilcox v Birmingham Cab Services Ltd UKEAT/0293/10/DMGlasson v The Insolvency Service [2024] EAT 5

Statutes

Equality Act 2010 s.21Equality Act 2010 s.20Equality Act 2010 s.212Equality Act 2010 s.136Equality Act 2010 Schedule 8 para 20

Case details

Case number
6001223/2023
Decision date
18 June 2024
Hearing type
full merits
Hearing days
3
Classification
contested

Respondent

Sector
hospitality
Represented
Yes
Rep type
barrister

Employment details

Role
Travel Advisor
Service
1 years

Claimant representation

Represented
No