Mrs B Hodgkiss v Blackpool Teaching Hospitals NHS Foundation Trust — 2025

This was a preliminary hearing before Employment Judge Phil Allen sitting alone on 13 February 2025. The judgment determined limitation and jurisdiction issues only. Mrs B Hodgkiss brought an unfair dismissal claim and disability discrimination complaints against Blackpool Teaching Hospitals NHS Foundation Trust.

The tribunal held that it did not have jurisdiction to hear the unfair dismissal claim because it had not been presented within the applicable time limit. The tribunal found it was reasonably practicable for the claim to have been presented in time, and the unfair dismissal claim was dismissed.

The tribunal also dealt with the disability discrimination complaints. One complaint of failure to make reasonable adjustments, described in the judgment as the allegation that following a report in March 2023 the claimant should not have been required to work on the furthest wards or on reception, was held to be out of time. The tribunal found it was not just and equitable to extend the time limit for that complaint, so it was dismissed.

The tribunal found that the claimant's other complaints of breach of the duty to make reasonable adjustments, together with her complaint of discrimination arising from disability, were also presented outside the primary time limit. However, it decided that it was just and equitable to extend time for those claims, and they were therefore allowed to proceed. No substantive merits findings or monetary award were made in this judgment.