Electronic Data Systems Ltd v Travis

Electronic Data Systems Ltd v Travis

The Tribunal was entitled to find that the employer failed to take reasonable steps to prevent disadvantage to the disabled employee by not providing training to update his skills. The Tribunal was not required to specify in detail the nature, cost, or duration of the training, as these matters were not made controversial by the employer at the hearing. The employer did not provide evidence that retraining would have been ineffective or that no alternative posts were available.

Parties
Appellant: Electronic Data Systems Ltd; Respondent: Dr Clive Hathaway Travis
Jurisdiction
England and Wales
Judgment Date
26 August 2004
Procedural Posture
Civil Appeal / Appeal From Employment Appeal Tribunal
Outcome
appeal dismissed
Legal Topics
Reasonable Adjustments, Redundancy, Unfair Dismissal, Duty to Disabled Employees
Employment Law Disability Discrimination Reasonable Adjustments Redundancy Unfair Dismissal Duty to Disabled Employees

Case Brief

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Parties

Electronic Data Systems Ltd

Appellant

Dr Clive Hathaway Travis

Respondent

Procedural Posture

Civil Appeal / Appeal From Employment Appeal Tribunal

Legal Issues

  1. 1 What level of detail must an Employment Tribunal provide when determining reasonable steps under section 6 of the Disability Discrimination Act 1995?
  2. 2 Did the employer fail to take reasonable steps to prevent disadvantage to a disabled employee?

Ratio Decidendi

The Tribunal was entitled to find that the employer failed to take reasonable steps to prevent disadvantage to the disabled employee by not providing training to update his skills. The Tribunal was not required to specify in detail the nature, cost, or duration of the training, as these matters were not made controversial by the employer at the hearing. The employer did not provide evidence that retraining would have been ineffective or that no alternative posts were available.

Court Disposition

appeal dismissed

Orders

  • Appellant to pay costs, summarily assessed in the sum of £8,000 plus VAT