Ms Denise Williams v DLRC Ltd — 2026

At the public preliminary hearing on 6 March 2026, the Tribunal refused Ms Williams's late application to postpone. It found that she knew by 14 January 2026 at the latest that medical advice indicated she could not attend, but did not apply until 4 March 2026. Applying Rules 32 and 47, the Tribunal found no exceptional circumstances justifying postponement and proceeded in her absence, while declining to dismiss the claim merely because she did not attend.

The pregnancy discrimination complaint was struck out under Rule 38. Despite oral and written orders and explanations of why the evidence was required, Ms Williams had not provided documents establishing the dates of the pregnancies relied upon. The Tribunal therefore could not identify the protected period and concluded that the complaint had no reasonable prospect of success, had not been actively pursued, and could not fairly be addressed by making a further order.

The automatic unfair dismissal complaint relying on pregnancy was struck out on corresponding grounds. The absence of evidence establishing the pregnancy dates meant that the complaint had no reasonable prospect of success, and the Tribunal also found repeated non-compliance with its orders and failure actively to pursue the complaint.

The wrongful dismissal complaint was struck out as having no reasonable prospect of success. The Tribunal found that DLRC Ltd communicated termination on 26 October 2023, paid sick pay until the fit note expired on 16 November 2023, and paid the equivalent of three months' notice. It also found that the contractual provisions permitted the notified deductions following Ms Williams's failure to return company property.

The Tribunal declined to strike out the race and religious discrimination complaints, including the race-related harassment allegation identified in the respondent's application. Applying Anyanwu and Ezsias, it considered that the conflicting factual accounts should be tested at trial. It nevertheless assessed the complaints as having little reasonable prospect of success because Ms Williams had not identified the required "something more" linking the alleged treatment to race or religion, explained less favourable treatment by comparison with a hypothetical comparator, or shown how the burden of proof would shift.

The deposit-order application concerning the continuing discrimination complaints was deferred because Rule 40 required reasonable enquiries into Ms Williams's ability to pay and she had not had an opportunity to provide that information. Subject to determination of that application, the complaints were listed to proceed in September 2026. No monetary award was made; £1,000 appeared only as the statutory maximum for a possible deposit order, and no deposit amount was set in this judgment.