R J Bryce v Active Security Solutions Limited & Anor

R J Bryce v Active Security Solutions Limited & Anor

The claimant did not establish that refusal of the requested adjustment prevented him from making any further or different submission on a material matter; Castano is binding and claimant was not 'designated' for health and safety purposes under section 44 ERA; Tribunal's error on detriment was academic as claimant was not protected by section 44(1) ERA.

Parties
Appellant: Mr R J Bryce; First Respondent: Active Security Solutions Limited; Second Respondent: Stonegate Pub Company Limited
Jurisdiction
England and Wales
Judgment Date
02 April 2026
Procedural Posture
Employment Appeal / Judgment on Appeal
Outcome
appeal refused
Legal Topics
Reasonable Adjustments, Procedural Fairness, Health and Safety Designation, Detriment, Strike Out Applications, Deposit Orders
Employment Law Disability Discrimination Reasonable Adjustments Procedural Fairness Health and Safety Designation Detriment Strike Out Applications Deposit Orders

Case Brief

Summary, issues, holding and outcome

More case intelligence is available

Unlock the full research layer for this judgment.

Full judgment text Downloadable case file Legal principles 4 Authorities cited 10 Party arguments 2 Amounts and remedies 1
Sign in to unlock

Parties

Mr R J Bryce

Appellant

Active Security Solutions Limited

First Respondent

Stonegate Pub Company Limited

Second Respondent

Procedural Posture

Employment Appeal / Judgment on Appeal

Legal Issues

  1. 1 Whether refusal to allow written submissions as a reasonable adjustment constituted procedural unfairness
  2. 2 Whether claimant was 'designated' for health and safety purposes under section 44 Employment Rights Act, 1996
  3. 3 Whether sending claimant home constituted a 'detriment' under section 44 Employment Rights Act, 1996

Ratio Decidendi

The claimant did not establish that refusal of the requested adjustment prevented him from making any further or different submission on a material matter; Castano is binding and claimant was not 'designated' for health and safety purposes under section 44 ERA; Tribunal's error on detriment was academic as claimant was not protected by section 44(1) ERA.

Court Disposition

appeal refused