Claimant v Respondent — 2026

Miss Williams was employed by South England Conference as a Bible Worker, and her contract permitted the Respondent to direct her to work at other locations. When the Respondent decided that Croydon no longer required a Bible Worker, it sought to deploy her to a vacancy at Brixton Church. The Tribunal found that the Brixton congregation's 2016 vote concerned the voluntary role of female Elder, not the employed role of Bible Worker, and was not a decision of the Respondent. It expressly did not determine the lawfulness of that vote.

The automatic unfair dismissal complaint under s.100(1)(d) ERA 1996 was dismissed. The Tribunal accepted that Miss Williams believed there were circumstances of danger to her mental health, but found that this belief was not reasonably held and that the alleged danger was not serious and imminent. Her belief that her duties would be restricted arose largely from general concerns and assumptions about the 2016 vote rather than specific evidence about working as a Bible Worker at Brixton. The Respondent's enquiries with the Pastor and Elders did not identify a danger.

For the reasonable-adjustments complaint, the Tribunal found that the Respondent could reasonably have been expected to know by mid-August 2019 that Miss Williams was disabled due to anxiety and was placed on notice of the substantial disadvantage by the Occupational Health report received at the end of November 2019. It found that the requirement to work at Brixton formed the context in which Miss Williams felt compelled to act against her will, triggering her disability-related symptoms, rather than the disadvantage arising from an intrinsic feature of Brixton or its duties. The Respondent investigated alternatives, but there was no continuing need at Croydon, no suitable alternative vacancy, and it would not have been reasonable to require another Bible Worker to move where this would affect her childcare. Remote working would neither have covered the full role nor avoided the identified disadvantage. The Tribunal therefore found no reasonable step had been omitted and dismissed the complaint.

The direct sex discrimination complaints concerning the Brixton deployment and dismissal were dismissed. The Tribunal found no facts supporting a prima facie case that Miss Williams was treated less favourably because of sex. It found that she was directed to Brixton because a Bible Worker was required there and was no longer required at Croydon, and that a hypothetical male Bible Worker who declined the same deployment on the equivalent grounds would have been treated in the same way, including dismissal.

On ordinary unfair dismissal, the Tribunal found that the principal reason was not misconduct but SOSR in the form of an impasse over redeployment. Miss Williams genuinely felt unable to comply after the instruction triggered disability-related symptoms, while the Respondent had no continuing need for her at Croydon and could not secure her deployment to Brixton. Over approximately 18 months, the Respondent discussed the issue with her, investigated her concerns, obtained Occupational Health input, explored other churches and a possible exchange with another Bible Worker, warned her that failure to accept the deployment would result in dismissal, and provided an appeal. The Tribunal found that the procedure and the decision to dismiss were within the band of reasonable responses and dismissed the ordinary unfair dismissal complaint.