University Of Bristol v Dr Robert Abrahart (Administrator of the estate of Natasha Abrahart, deceased)

University Of Bristol v Dr Robert Abrahart (Administrator of the estate of Natasha Abrahart, deceased)

The University breached its duty to make reasonable adjustments under the Equality Act 2010 by failing to proactively alter oral assessment requirements for Natasha Abrahart, despite clear knowledge of her disability and its impact. Oral assessments were not competence standards but methods of assessment, and reasonable adjustments such as written responses or alternative formats should have been implemented. The University's reliance on internal procedures and lack of formal diagnosis did not justify its inaction. The appeal is dismissed; the County Court's findings stand.

Parties
Appellant/defendant: The University of Bristol; Claimant/respondent: Dr Robert Abrahart (Administrator of the estate of Natasha Abrahart, deceased); Intervener: Equality and Human Rights Commission
Jurisdiction
England and Wales
Judgment Date
11 October 2024
Procedural Posture
Appeal / High Court Review of County Court Judgment
Outcome
Appeal dismissed; County Court judgment upheld.
Legal Topics
Reasonable Adjustments, Competence Standards, Indirect Discrimination, Discrimination Arising From Disability, Duty of Care, Confidentiality
Disability Discrimination Education Law Tort Law Reasonable Adjustments Competence Standards Indirect Discrimination Discrimination Arising From Disability Duty of Care +1 more

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Parties

The University of Bristol

Appellant/defendant

Dr Robert Abrahart (Administrator of the estate of Natasha Abrahart, deceased)

Claimant/respondent

Equality and Human Rights Commission

Intervener

Procedural Posture

Appeal / High Court Review of County Court Judgment

Legal Issues

  1. 1 Whether the University breached its duty to make reasonable adjustments under the Equality Act 2010
  2. 2 Whether oral assessments constituted a competence standard exempt from adjustment
  3. 3 Whether the University had actual or constructive knowledge of the claimant's disability

Ratio Decidendi

The University breached its duty to make reasonable adjustments under the Equality Act 2010 by failing to proactively alter oral assessment requirements for Natasha Abrahart, despite clear knowledge of her disability and its impact. Oral assessments were not competence standards but methods of assessment, and reasonable adjustments such as written responses or alternative formats should have been implemented. The University's reliance on internal procedures and lack of formal diagnosis did not justify its inaction. The appeal is dismissed; the County Court's findings stand.

Court Disposition

Appeal dismissed; County Court judgment upheld.

Orders

  • Damages of £50,000 for pain, suffering, loss of amenity, and injury to feelings awarded to the claimant.
  • Parties to agree a sum in respect of funeral expenses.