Jack Truman v SPL Powerlines UK Limited & Ors

Jack Truman v SPL Powerlines UK Limited & Ors

Network Rail is a qualifications body under the Equality Act 2010 as the Sentinel card is a relevant qualification needed for safety-critical roles in the rail industry. The requirement to pass a drug and alcohol test is a competence standard, and the process for adjusting for legitimate medication is not part of the standard itself. The Employment Tribunal erred in its analysis of substantial disadvantage as against Network Rail and the issue is remitted for reconsideration. Express Medicals cannot be liable under ss.111/112 as the statutory relationship requirements are not met. The findings on responsibility and proportionality were not perverse.

Parties
Appellant: Mr Jack Truman; First Respondent: SPL Powerlines UK Limited; Second Respondent: Network Rail Infrastructure Limited; Third Respondent: Express Medicals Limited
Jurisdiction
England and Wales
Judgment Date
01 May 2026
Procedural Posture
Employment Appeal / Judgment on Appeal and Cross Appeals
Outcome
Appeal allowed in part, cross-appeals allowed in part, remittal ordered
Legal Topics
Disability Discrimination, Reasonable Adjustments, Qualifications Body, Drug and Alcohol Testing, Comparator Analysis, Statutory Interpretation
Employment Law Equality and Discrimination Disability Discrimination Reasonable Adjustments Qualifications Body Drug and Alcohol Testing Comparator Analysis Statutory Interpretation

Case Brief

Summary, issues, holding and outcome

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Parties

Mr Jack Truman

Appellant

SPL Powerlines UK Limited

First Respondent

Network Rail Infrastructure Limited

Second Respondent

Express Medicals Limited

Third Respondent

Procedural Posture

Employment Appeal / Judgment on Appeal and Cross Appeals

Legal Issues

  1. 1 Whether Network Rail is a 'qualifications body' under the Equality Act 2010
  2. 2 Whether the requirement to pass a drug and alcohol test is a 'competence standard' under s.53(7) EqA
  3. 3 Whether the claimant was put to a substantial disadvantage compared to non-disabled persons under s.20 EqA

Ratio Decidendi

Network Rail is a qualifications body under the Equality Act 2010 as the Sentinel card is a relevant qualification needed for safety-critical roles in the rail industry. The requirement to pass a drug and alcohol test is a competence standard, and the process for adjusting for legitimate medication is not part of the standard itself. The Employment Tribunal erred in its analysis of substantial disadvantage as against Network Rail and the issue is remitted for reconsideration. Express Medicals cannot be liable under ss.111/112 as the statutory relationship requirements are not met. The findings on responsibility and proportionality were not perverse.

Court Disposition

Appeal allowed in part, cross-appeals allowed in part, remittal ordered

Orders

  • Mr Truman's appeal on the competence standard issue is dismissed.
  • Mr Truman's appeal on the substantial disadvantage/comparator issue is dismissed as against Powerlines but allowed as against Network Rail; Issues 24 and 25 are remitted to the Employment Tribunal for reconsideration.