Phullar v Ofsted (UNFAIR DISMISSAL; DISABILITY DISCRIMINATION) [2026] EAT 10 (14 January 2026)

Phullar v Ofsted (UNFAIR DISMISSAL; DISABILITY DISCRIMINATION) [2026] EAT 10 (14 January 2026)

The Employment Tribunal erred in law by applying the wrong test to the section 15 Equality Act 2010 claim, failed to provide adequate reasons for its conclusions on reasonable adjustments and unfair dismissal, and made conflicting or insufficient findings regarding alternative roles and the effect of adjustments. The appeal and cross-appeal both succeeded, and the relevant claims are remitted for fresh adjudication.

Citation
[2026] EAT 10
Parties
Appellant/cross Respondent: Ms R Phullar; Respondent/cross Appellant: Ofsted
Jurisdiction
United Kingdom
Judgment Date
14 January 2026
Procedural Posture
Employment Appeal Tribunal / Appeal From Employment Tribunal Judgment
Outcome
Appeal and cross-appeal allowed; relevant claims remitted for fresh adjudication.
Legal Topics
Unfair Dismissal, Disability Discrimination, Reasonable Adjustments, Section 15 Equality Act 2010, Section 20 Equality Act 2010, Employment Rights Act 1996, Employment Tribunal Procedure
Employment Law Equality Law Unfair Dismissal Disability Discrimination Reasonable Adjustments Section 15 Equality Act 2010 Section 20 Equality Act 2010 Employment Rights Act 1996 +1 more

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 5 Authorities cited 15 Party arguments 2 Amounts and remedies 2
Sign in to unlock

Parties

Ms R Phullar

Appellant/cross Respondent

Ofsted

Respondent/cross Appellant

Procedural Posture

Employment Appeal Tribunal / Appeal From Employment Tribunal Judgment

Legal Issues

  1. 1 Whether the Employment Tribunal erred in law in dismissing the section 15 Equality Act 2010 discrimination claim
  2. 2 Whether the Employment Tribunal's reasoning on reasonable adjustments was Meek-compliant
  3. 3 Whether the Employment Tribunal erred in its approach to alternative roles and redeployment

Ratio Decidendi

The Employment Tribunal erred in law by applying the wrong test to the section 15 Equality Act 2010 claim, failed to provide adequate reasons for its conclusions on reasonable adjustments and unfair dismissal, and made conflicting or insufficient findings regarding alternative roles and the effect of adjustments. The appeal and cross-appeal both succeeded, and the relevant claims are remitted for fresh adjudication.

Court Disposition

Appeal and cross-appeal allowed; relevant claims remitted for fresh adjudication.

Orders

  • The decisions dismissing the section 15 Equality Act 2010 claim, the unfair dismissal claim, and certain reasonable adjustment claims are set aside.
  • The decisions upholding certain reasonable adjustment claims are also set aside.