Truman v SPL Powerlines UK Ltd & Ors (DISABILITY DISCRIMINATION) [2026] EAT 54 (01 May 2026)

Truman v SPL Powerlines UK Ltd & Ors (DISABILITY DISCRIMINATION) [2026] EAT 54 (01 May 2026)

Network Rail is a qualifications body under the Equality Act 2010 because the Sentinel card is an authorisation needed to work in a safety-critical rail role, which constitutes a relevant qualification. The D&A test is a competence standard, so its application is not direct disability discrimination under s.15 EqA. However, the Employment Tribunal erred in its approach to substantial disadvantage under s.20 EqA; the requirement to pass the D&A test could put disabled persons using prescribed medication at a substantial disadvantage. The appeal on this issue against Network Rail is allowed and remitted for reconsideration. Express Medicals is not liable under s.111(7) EqA as it was not in...

Citation
[2026] EAT 54
Parties
Appellant: Mr Jack Truman; First Respondent: SPL Powerlines UK Limited; Second Respondent: Network Rail Infrastructure Limited; Third Respondent: Express Medicals Limited
Jurisdiction
United Kingdom
Judgment Date
01 May 2026
Procedural Posture
Employment Appeal Tribunal (eat) Appeal / Judgment on Appeal and Cross Appeals
Outcome
Appeal allowed in part; cross-appeals dismissed in part; matter remitted to Employment Tribunal for reconsideration of the s.20 EqA claim against Network Rail.
Legal Topics
Disability Discrimination, Reasonable Adjustments, Qualifications Body, Competence Standard, Drug and Alcohol Testing, Medical Cannabis, Employment Recruitment, Appeals Process
Employment Law Equality and Discrimination Law Disability Discrimination Reasonable Adjustments Qualifications Body Competence Standard Drug and Alcohol Testing Medical Cannabis +2 more

Case Brief

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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 Tribunal (eat) Appeal / Judgment on Appeal and Cross Appeals

Legal Issues

  1. 1 Whether Network Rail is a 'qualifications body' under ss.53/54 Equality Act 2010 (EqA)
  2. 2 Whether the application of the drug and alcohol (D&A) test was a 'competence standard' under s.53(7) EqA
  3. 3 Whether the claimant was put at a substantial disadvantage for the purposes of s.20 EqA

Ratio Decidendi

Network Rail is a qualifications body under the Equality Act 2010 because the Sentinel card is an authorisation needed to work in a safety-critical rail role, which constitutes a relevant qualification. The D&A test is a competence standard, so its application is not direct disability discrimination under s.15 EqA. However, the Employment Tribunal erred in its approach to substantial disadvantage under s.20 EqA; the requirement to pass the D&A test could put disabled persons using prescribed medication at a substantial disadvantage. The appeal on this issue against Network Rail is allowed and remitted for reconsideration. Express Medicals is not liable under s.111(7) EqA as it was not in...

Court Disposition

Appeal allowed in part; cross-appeals dismissed in part; matter remitted to Employment Tribunal for reconsideration of the s.20 EqA claim against Network Rail.

Orders

  • Claimant's appeal on the s.20 'substantial disadvantage' issue against Network Rail allowed and remitted for reconsideration.
  • Claimant's appeal on the 'competence standard' issue dismissed.