Dr A. Chowdhury v Dr Fernandes and Partners and 2 others — 2025

The claimant worked as a salaried GP from 3 August 2022 to 20 September 2022. The tribunal accepted that she had repetitive strain injury, and that it had a substantial adverse effect on her day-to-day activities earlier in 2022, but found that the effects were not long-term by August and September 2022. It therefore held that she was not a disabled person at the relevant time for the purposes of section 6 Equality Act 2010.

Even if that conclusion was wrong, the reasonable adjustments complaint failed. The tribunal accepted that the requirement to undertake patient appointments as scheduled could place the claimant at a disadvantage in telephone consultations, but not in face-to-face consultations. It found the respondent did not have the relevant knowledge until 17 August 2022, and that the proposed adjustments either were agreed or could have been implemented, were not needed, or were not reasonable in the circumstances, including breaks between appointments, physiotherapy, longer appointments, reduced administration tasks, a headset or dictaphone, and an ergonomic keyboard.

The section 15 claim also failed. The tribunal found that, although the claimant had sought workplace adjustments, the dismissal on 20 September 2022 was driven by the way she interacted with the partners, which they perceived as negative and critical, and by a clash of personalities and expectations. The tribunal did not accept that the dismissal was because of the claimant's request for adjustments.

The unlawful deduction from wages claim succeeded only in part. The respondent accepted that it had inadvertently underpaid the claimant's basic salary, and the tribunal found that £815.01 gross was properly due and unpaid in her September 2022 pay. The tribunal rejected the holiday pay element and held that the pension contribution complaint did not fall within the wages jurisdiction, referring to Somerset County Council v Chambers. The claimant was awarded £815.01 gross, with tax and National Insurance to be dealt with by her.