Jayaram v Network Rail Infrastructure Ltd (RACE DISCRIMINATION) [2020] UKEAT 0164_19_2401 (24 January 2020)

Jayaram v Network Rail Infrastructure Ltd (RACE DISCRIMINATION) [2020] UKEAT 0164_19_2401 (24 January 2020)

The Employment Tribunal did not fail in its duty to ensure effective participation of disabled persons. The process was agreed based on the Claimant being unrepresented, not disabled. No evidence was provided to establish the nature and extent of the disability or the need for adjustments. The Tribunal's findings were based on the evidence of the Respondent's witnesses regarding interview scoring, not on the Claimant's credibility or manner of giving evidence.

Citation
[2020] UKEAT 0164_19_2401
Parties
Appellant: Mr Jayaram; Respondent: Network Rail Infrastructure Ltd
Jurisdiction
United Kingdom
Judgment Date
24 January 2020
Procedural Posture
Employment Appeal Tribunal / Appeal Against Employment Tribunal Decision
Outcome
Appeal dismissed
Legal Topics
Race Discrimination, Disability Discrimination, Reasonable Adjustments, Fair Hearing
Employment Law Equality Law Race Discrimination Disability Discrimination Reasonable Adjustments Fair Hearing

Case Brief

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Parties

Mr Jayaram

Appellant

Network Rail Infrastructure Ltd

Respondent

Procedural Posture

Employment Appeal Tribunal / Appeal Against Employment Tribunal Decision

Legal Issues

  1. 1 Whether the Employment Tribunal failed to provide the Claimant with a fair hearing by not accommodating his ADHD-related needs
  2. 2 Whether the Employment Tribunal failed to take sufficient account of the Claimant's disabilities and/or adjustments in its conclusions

Ratio Decidendi

The Employment Tribunal did not fail in its duty to ensure effective participation of disabled persons. The process was agreed based on the Claimant being unrepresented, not disabled. No evidence was provided to establish the nature and extent of the disability or the need for adjustments. The Tribunal's findings were based on the evidence of the Respondent's witnesses regarding interview scoring, not on the Claimant's credibility or manner of giving evidence.

Court Disposition

Appeal dismissed

Orders

  • No further action; Employment Tribunal decision stands