Mr W Iqbal v Mazars LLP — 2021

This was a preliminary hearing on whether Mr W Iqbal was disabled by reason of dyslexia. The tribunal accepted that he had dyslexia and that it was long term, but the statutory question was whether it had a substantial adverse effect on his ability to carry out normal day-to-day activities. The tribunal referred to section 6 and section 212 of the Equality Act 2010, the Government guidance on disability, and the approach in Paterson v Commissioner of Police of the Metropolis and Chacón Navas v Eurest Colectividades SA.

Mr Iqbal had joined Mazars LLP in July 2019 to train as a chartered tax adviser. After performance concerns arose, he said he might have dyslexia and an assessment was arranged. The BDA assessment dated 11 March 2020 found dyslexia and recommended, among other things, 25% extra time in exams and other adjustments. The tribunal accepted that the assessment was factually accurate and treated it as its starting point.

The tribunal found that many of the difficulties described by Mr Iqbal were minor, commonplace, or capable of being addressed by modest adjustments in everyday life. It also found that some of the work-related performance issues were not connected with dyslexia, including deadlines and prioritisation issues. Although the tribunal accepted that there was some effect on reading, writing, and examinations, it held that the impact was not more than minor or trivial when looked at cumulatively.

A material part of the reasoning was that Mr Iqbal had been able to obtain a degree and qualify as a chartered accountant before any diagnosis, and that he had still not passed his later examination even with 25% extra time. The tribunal concluded that the higher-level tax adviser qualification was a specialised activity and that, on the evidence, dyslexia was not preventing him from participating in normal day-to-day activities to the required substantial degree. It therefore held that he was not disabled for Equality Act purposes and dismissed the claim.