Cases2300751/2023

Claimant v Maidstone Borough Council

5 February 2024Before Employment Judge T.R. SmithLondon Southremote video

Outcome

Claimant fails

Individual claims

Whistleblowingnot determined

This was a preliminary hearing on disability status only. The tribunal determined the claimant was not disabled within the meaning of s6 Equality Act 2010 in respect of ADHD, endometriosis, or stress fracture. The substantive whistleblowing claims were not heard. The respondent conceded disability in respect of dyslexia.

Automatic Unfair Dismissalnot determined

This was a preliminary hearing on disability status only. The tribunal determined the claimant was not disabled within the meaning of s6 Equality Act 2010 in respect of ADHD, endometriosis, or stress fracture. The substantive automatic unfair dismissal claim was not heard.

Direct Discrimination(disability)not determined

The tribunal found the claimant was not a disabled person at the relevant time in respect of ADHD, endometriosis, or stress fracture. The respondent conceded disability in respect of dyslexia. The substantive direct disability discrimination claims were not determined at this hearing.

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

The tribunal found the claimant was not a disabled person at the relevant time in respect of ADHD, endometriosis, or stress fracture. The respondent conceded disability in respect of dyslexia. The substantive s15 claims were not determined at this hearing.

Failure to Make Reasonable Adjustments(disability)not determined

The tribunal found the claimant was not a disabled person at the relevant time in respect of ADHD, endometriosis, or stress fracture. The respondent conceded disability in respect of dyslexia. The substantive reasonable adjustments claims were not determined at this hearing.

Harassment(disability)not determined

The tribunal found the claimant was not a disabled person at the relevant time in respect of ADHD, endometriosis, or stress fracture. The respondent conceded disability in respect of dyslexia. The substantive harassment related to disability claims were not determined at this hearing.

Direct Discrimination(sex)not determined

This was a preliminary hearing on disability status only. The substantive sex discrimination claims were not heard at this preliminary hearing.

Harassment(sex)not determined

This was a preliminary hearing on disability status only. The substantive harassment related to sex claims were not heard at this preliminary hearing.

Victimisationnot determined

This was a preliminary hearing on disability status only. The substantive victimisation claims were not heard at this preliminary hearing.

Facts

The claimant worked as a waste crime officer for Maidstone Borough Council from June 2022 to January 2023. She was absent from work from 30 September 2022 until dismissal, principally due to stress. The respondent conceded the claimant was disabled in respect of dyslexia. The claimant asserted she was also disabled due to ADHD (diagnosed May 2022), endometriosis (diagnosis date disputed between 2014, 2016, and 2023), and a stress fracture (sustained January 2023, diagnosed March 2023 after employment ended). The tribunal found the claimant's evidence confused and contradictory, with significant gaps in medical evidence.

Decision

The tribunal found the claimant was not a disabled person at the relevant time in respect of ADHD, endometriosis, or stress fracture. The stress fracture occurred after employment ended. While ADHD was a mental impairment with long-term effect, the claimant failed to establish it had a substantial adverse effect on day-to-day activities—her examples were minor and similar to what non-disabled people experience. For endometriosis, the claimant provided virtually no examples of substantial effect, had no work absence due to it, and the tribunal could not be satisfied it was long-term given surgical intervention.

Practical note

A diagnosis of a condition does not automatically satisfy the statutory definition of disability under s6 Equality Act 2010; claimants must provide clear, cogent evidence with adequate medical support that the condition has a substantial (more than trivial) and long-term adverse effect on normal day-to-day activities.

Legal authorities cited

Goodwin v Patent Office [1999] ICR 302Cruickshank v VAW Motorcast Ltd [2002] ICR 729Tesco Stores Ltd v Tennant [2020] IRLR 363Boyle v SCA Packaging Ltd [2009] IRLR 746Sullivan v Bury Street Capital Ltd [2020] IRLR 953McDougall v Richmond Adult Community College [2008] EWCA Civ 4Chief Constable of Dumfries and Galloway Constabulary v Adams [2009] ICR 1034Law Hospital NHS Trust v Rush [2001] ICR 1034Woodrup v Southwark London Borough Council [2003] IRLR 111Leonard v South Derbyshire Centre of Commerce [2001] IRLR 19

Statutes

Equality Act 2010 s.26Equality Act 2010 s.27Equality Act 2010 s.6Equality Act 2010 Schedule 1Employment Rights Act 1996 s.48Employment Rights Act 1996 s.103AEquality Act 2010 s.13Equality Act 2010 s.15Equality Act 2010 s.20Equality Act 2010 s.21

Case details

Case number
2300751/2023
Decision date
5 February 2024
Hearing type
preliminary
Hearing days
1
Classification
contested

Respondent

Sector
public sector
Represented
Yes
Rep type
barrister

Employment details

Role
Waste crime officer
Service
7 months

Claimant representation

Represented
No