Cases4110210/2021

Claimant v Carers Direct Ltd

10 June 2024Before Employment Judge C McManusScotlandremote video

Outcome

Claimant fails

Individual claims

Whistleblowingstruck out

The claim was struck out under Rule 37 for non-compliance with multiple case management orders over a three-year period, failure to actively pursue the claim, and unreasonable conduct including repeated late postponement requests. The claimant failed to provide particulars of her claim, failed to attend hearings, and did not comply with orders despite multiple extensions and accommodations for her health issues.

Detrimentstruck out

The detriment claim under sections 44(1)(c) and 47 ERA 1996 was struck out alongside the whistleblowing claim for the same reasons: persistent non-compliance with case management orders, failure to actively pursue the claim despite the case being ongoing since 2021, and unreasonable conduct in the manner of conducting proceedings.

Facts

The claimant, a Polish speaker, filed a whistleblowing claim in June 2021 relating to events in 2020. Over nearly three years, she repeatedly failed to comply with case management orders requiring particulars of her claim, failed to provide a schedule of loss, and requested multiple postponements of hearings citing physical and mental health issues. Despite extensive accommodations including sisting proceedings multiple times, providing Polish interpreters, and granting extensions, the claimant never provided the required information. She had received legal advice before filing but gave no detail of her whistleblowing complaint. On the day of the final strike-out hearing in June 2024, she failed to attend despite having video joining instructions.

Decision

The tribunal struck out the claim under Rule 37(b), (c), and (d) for non-compliance with multiple case management orders, unreasonable conduct in repeatedly seeking late postponements without proper justification, and failure to actively pursue the claim. The judge balanced the interests of both parties and concluded that the claimant had been given extensive opportunities to comply over three years but provided no indication of intention or ability to comply, while the respondent faced prejudice from delay and staff turnover affecting the possibility of a fair hearing.

Practical note

Even where a claimant has genuine health issues and language barriers, tribunals will strike out claims where there is persistent and unexplained non-compliance with case management orders over an extended period, particularly where the claimant fails to engage with the proceedings despite extensive accommodations and the respondent faces increasing prejudice from delay.

Legal authorities cited

Anghel v Middlesex University 2022 EAT 176Baber v RBS plc 0301/05 EATEmuemukoro v Croma Vigilant Scotland LtdSmith v Tesco Stores Ltd 2023 EAT 11Bliss Residential Care Ltd v Fellows 2003 EAT 8Ian Pearce v Bank of America Merrill LynchRoyal Bank of Scotland plc v Theobald 2007 EAT 444

Statutes

ERA 1996 s.47B(1)ERA 1996 s.44(1)(c)ERA 1996 s.48(1)Employment Tribunals Rules Rule 92Employment Tribunals Rules Rule 2Employment Tribunals (Constitution and Rules of Procedure) Regulations 2013 Rule 37ERA 1996 s.47(1A)

Case details

Case number
4110210/2021
Decision date
10 June 2024
Hearing type
strike out
Hearing days
1
Classification
procedural

Respondent

Sector
healthcare
Represented
Yes
Rep type
solicitor

Claimant representation

Represented
No