Ridge v Land Registry [2010] UKEAT 0382_09_1903 (19 March 2010)

Ridge v Land Registry [2010] UKEAT 0382_09_1903 (19 March 2010)

The Tribunal erred by failing to consider the actual comparators identified by the Claimant in relation to discretionary payment systems, requiring remission. The Tribunal correctly dismissed the claims regarding reasonable adjustments for open plan office working and retraining, as the Claimant was not at a substantial disadvantage and the factual basis for those claims was not made out.

Citation
[2010] UKEAT 0382_09_1903
Parties
Appellant/claimant: Clive Ridge; Respondent: Land Registry (Respondent)
Jurisdiction
United Kingdom
Judgment Date
19 March 2010
Procedural Posture
Employment Appeal / Appeal Judgment Following Employment Tribunal Decision
Outcome
Appeal allowed in part by consent; remission ordered on comparators issue; other grounds dismissed.
Legal Topics
Direct Disability Discrimination, Disability Related Discrimination, Reasonable Adjustments, Comparators in Discrimination Claims
Employment Law Disability Discrimination Direct Disability Discrimination Disability Related Discrimination Reasonable Adjustments Comparators in Discrimination Claims

Case Brief

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Parties

Clive Ridge

Appellant/claimant

Land Registry (Respondent)

Respondent

Procedural Posture

Employment Appeal / Appeal Judgment Following Employment Tribunal Decision

Legal Issues

  1. 1 Whether the Employment Tribunal erred in failing to consider actual comparators in a disability discrimination claim
  2. 2 Whether the Respondent failed to make reasonable adjustments regarding open plan office working and retraining on 'Business Objects' software

Ratio Decidendi

The Tribunal erred by failing to consider the actual comparators identified by the Claimant in relation to discretionary payment systems, requiring remission. The Tribunal correctly dismissed the claims regarding reasonable adjustments for open plan office working and retraining, as the Claimant was not at a substantial disadvantage and the factual basis for those claims was not made out.

Court Disposition

Appeal allowed in part by consent; remission ordered on comparators issue; other grounds dismissed.

Orders

  • Remit the issue of comparators in discretionary payment systems to the same Employment Tribunal for reconsideration.
  • Claims regarding reasonable adjustments for open plan office working and retraining dismissed.