Case 1403497/2022 · Employment Tribunal
Claimant v Paul Steele Ltd — 2023
- Case reference
- 1403497/2022
- Decision date
- 1 December 2023
- Jurisdiction
- England & Wales
- Judge
- Employment Judge Housego Representation
- Venue
- Bristol
Parties
2 namedClaimant
Claimant
Respondent
Key findings
Tribunal's reasoningThis was a preliminary hearing on time limits and amendment, not a merits hearing. The claimant's existing pleaded case included pregnancy discrimination and protected disclosure detriment, and the Employment Judge added automatic unfair dismissal under s.103A ERA 1996 and implicit automatically unfair constructive dismissal from the pleaded narrative of resignation. The judge also recorded an anonymity order for the claimant.
Claims and outcomes
6 findings recorded| Claim type | Issue or finding | Outcome | Protected characteristic | Award |
|---|---|---|---|---|
| Pregnancy and maternity discrimination | Existing claim in the claim form; the preliminary hearing decided amendment and time-limit issues only. The tribunal did not determine liability, but held that no part of the claim should be struck out and that any out-of-time issue would be met by a just and equitable extension. | Other | Pregnancy and maternity | — |
| Whistleblowing | Claim under protected disclosure detriment was treated as in time and allowed to proceed. The tribunal did not decide the merits at this hearing. | Other | — | — |
| Unfair dismissal | The Employment Judge added an automatic unfair dismissal claim under s.103A ERA 1996 of the tribunal's own volition because it was implicit in the pleaded facts. Merits were not determined at this hearing. | Other | — | — |
| Constructive dismissal | The tribunal treated automatically unfair constructive dismissal as implicit in the pleaded narrative of resignation. No merits determination was made. | Other | — | — |
| Sex discrimination | Leave to amend was granted to add sex discrimination based on the facts referred to in the claim form, the grievance, and the claimant's email. The tribunal held the amendment was not a mere relabelling exercise but a new claim, and did not decide liability. | Other | Sex | — |
| Harassment | Leave to amend was granted to add harassment claims. The tribunal held harassment was not a relabelling exercise and referred to the different test under s.26 Equality Act 2010. Liability was not determined at this hearing. |
Legal tests applied
4 references- Selkent principles
- Reuters Ltd v Cole [2018] UKEAT 0258_17_1602
- Bakkali v Greater Manchester Buses (South) Ltd [2018] UKEAT 0176_17_1005
- just and equitable extension of time
Official outcome judgment PDF
Gov.uk primary recordThe official judgment PDF on gov.uk contains the tribunal's outcome, reasoning, and any remedy details. Where this page does not yet show extracted outcomes for every claim, use the PDF as the authoritative source.
Published on gov.uk under the Open Government Licence v3.0.
How we got this data
Case essentials (reference, date, judge, venue, country, claim categories) are extracted from the structured metadata gov.uk publishes alongside each decision. Parties and monetary figures are extracted from the judgment PDF text. Key findings and per-claim outcomes require a second extraction pass that is not yet complete for this case — until then, the primary source linked above is the authoritative record. See full methodology.
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