In person For the v Respondent — 2025

The claimant, Ms Sandra Chamberlain, was employed by the respondent as an Advice Session Supervisor and had previously been found to be a disabled person by reason of ADHD. After a redundancy process in early 2023 she was reinstated with reasonable adjustments, including a three-day working pattern. In July 2023 Mrs Lisa Joyce, the Interim Operations Manager, asked the claimant and Mr Keith Sheldrake to prepare a flowchart of the General Advice section by Friday 14 July 2023. The tribunal found that neither of them started the task, that neither raised with Mrs Joyce or Miss Rebecca Bell that they needed more time or a disability-related adjustment, and that they found time to discuss complaints about Mrs Joyce instead.

On 12 July 2023 there was a confrontation between Mrs Joyce and the claimant. The tribunal heard three slightly different accounts and did not resolve the exact words used, but it found that Mrs Joyce concluded the claimant had failed to act on a reasonable management instruction and had undermined her authority in front of junior colleagues. Mrs Joyce dismissed the claimant summarily on 13 July 2023 for poor conduct and failure to follow reasonable management instructions, later confirming four weeks' pay in lieu of notice. The tribunal accepted that Mrs Joyce personally did not know at the time that the claimant had ADHD, and found that the dismissal decision was not based on the claimant's disability.

The discrimination arising from disability claim therefore failed. Applying the authorities it had cited, including Pnaiser and Grosset, the tribunal held that the claimant was not dismissed because of any something arising in consequence of ADHD. Even if an inability to complete the flowchart within the suggested timescale could have been such a something, the tribunal found that was not the reason for dismissal: the reason was the claimant's conduct, including her response to Mrs Joyce. The claimant had also confirmed that her comments to Mrs Joyce were not related to ADHD.

The reasonable adjustments claim also failed. The claimant relied on two PCPs: requiring the flowchart to be produced by a short deadline, and calling disciplinary meetings without advance warning. The tribunal held that the flowchart instruction was a one-off management instruction and not a PCP, and that there was no evidence of a general practice of calling disciplinary meetings without warning. It further found that no substantial disadvantage compared with non-disabled employees was established in relation to either alleged PCP, so the duty to make reasonable adjustments was not engaged and the claim was dismissed.