J W Rackham v NHS Professionals Ltd [2015] UKEAT 0110_15_1612 (16 December 2015)

J W Rackham v NHS Professionals Ltd [2015] UKEAT 0110_15_1612 (16 December 2015)

The Tribunal did not err in law by failing to obtain an expert report, as sufficient evidence and agreement existed regarding reasonable adjustments, and the claimant's autonomy and GP endorsement supported the adequacy of measures taken. The Tribunal properly considered fairness, proportionality, and the Equal Treatment Bench Book.

Citation
[2015] UKEAT 0110_15_1612
Parties
Appellant: Mr Rackham; Respondent: NHS Professionals Ltd
Jurisdiction
United Kingdom
Judgment Date
16 December 2015
Procedural Posture
Employment Appeal Tribunal / Appeal From Employment Tribunal Preliminary Hearing
Outcome
Appeal dismissed
Legal Topics
Reasonable Adjustments, Fair Hearing, Bias, Procedural Irregularity, Disability Definition, Access to Justice
Employment Law Disability Discrimination Procedural Law Reasonable Adjustments Fair Hearing Bias Procedural Irregularity Disability Definition +1 more

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Parties

Mr Rackham

Appellant

NHS Professionals Ltd

Respondent

Procedural Posture

Employment Appeal Tribunal / Appeal From Employment Tribunal Preliminary Hearing

Legal Issues

  1. 1 Whether the Tribunal erred in law by failing to obtain an expert report on reasonable adjustments for a disabled claimant
  2. 2 Whether the adjustments made were adequate to ensure a fair hearing
  3. 3 Whether there was a failure to follow the Equal Treatment Bench Book

Ratio Decidendi

The Tribunal did not err in law by failing to obtain an expert report, as sufficient evidence and agreement existed regarding reasonable adjustments, and the claimant's autonomy and GP endorsement supported the adequacy of measures taken. The Tribunal properly considered fairness, proportionality, and the Equal Treatment Bench Book.

Court Disposition

Appeal dismissed