Mr Sering Sallah v Uob Security Services Ltd — 2025

This was a reserved judgment following a preliminary hearing before Employment Judge Dennehy on 1 December 2025, the fourth preliminary hearing in the matter. The Tribunal had to decide whether it was just and equitable to extend time to allow the claimant's complaints of race-related harassment and victimisation to proceed, and whether to strike out the claims for non-compliance with case management orders and for failing to actively pursue the case under rules 38(1)(c) and 38(1)(d). The unfair dismissal claim had previously been struck out at the first preliminary hearing because the claimant lacked two years' service.

On time limits, the Tribunal found it just and equitable to extend time. The judgment records that the claimant's grievance had been partially upheld by the respondent, that the claimant is a litigant in person who had been seeking assistance from ACAS and a trade union representative, and that the ET1 was filed nine days out of time following ACAS early conciliation. The Tribunal concluded that the complaints of race-related harassment and victimisation should proceed to the final hearing listed for 21-24 July 2026.

On strike out, the Tribunal refused the respondent's application. Although there had been non-compliance with case management orders, the claimant had by 25 November 2025 provided a witness statement and appeared to be actively pursuing his claim. The Tribunal found that a fair hearing was still possible, that strike out would not be proportionate, and that the claim did not have little reasonable prospect of success such as to warrant a deposit order. No deposit order was made.