iForce Ltd v Wood (Disability related discrimination) [2019] UKEAT 0167_18_0301 (3 January 2019)

iForce Ltd v Wood (Disability related discrimination) [2019] UKEAT 0167_18_0301 (3 January 2019)

The Employment Tribunal failed to establish a causal connection between the claimant's disability and her erroneous belief regarding workplace conditions; without evidence that the disability impaired her judgment or caused the mistaken belief, section 15 Equality Act 2010 was not satisfied.

Citation
[2019] UKEAT 0167_18_0301
Parties
Appellant: Claimant; Respondent: Respondent
Jurisdiction
United Kingdom
Judgment Date
03 January 2019
Procedural Posture
Employment Appeal / Full Hearing of Appeal
Outcome
appeal allowed
Legal Topics
Disability Discrimination, Equality Act 2010 Section 15, Causation in Discrimination Claims
Employment Law Discrimination Law Disability Discrimination Equality Act 2010 Section 15 Causation in Discrimination Claims

Case Brief

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Parties

Claimant

Appellant

Respondent

Respondent

Procedural Posture

Employment Appeal / Full Hearing of Appeal

Legal Issues

  1. 1 Whether the claimant's refusal to comply with a management instruction arose in consequence of her disability for purposes of section 15 Equality Act 2010
  2. 2 Whether an erroneous belief can constitute 'something' arising from disability under section 15 EqA

Ratio Decidendi

The Employment Tribunal failed to establish a causal connection between the claimant's disability and her erroneous belief regarding workplace conditions; without evidence that the disability impaired her judgment or caused the mistaken belief, section 15 Equality Act 2010 was not satisfied.

Court Disposition

appeal allowed

Orders

  • Employment Tribunal's decision under section 15 Equality Act 2010 set aside