Mr R Black v Greater Glasgow Health Board — 2026

Mr Black brought disability discrimination claims arising from his employment with Greater Glasgow Health Board. He was diagnosed with autism in 2019, and the respondent accepted that he was disabled under the Equality Act 2010 during the relevant period. The preliminary hearing dealt only with whether the claims were in time, not their merits.

Mr Black had worked as a Healthcare Support Worker in the Theatres department until 20 May 2022, when he moved to a permanent role with the Vaccinations team after time on the redeployment register. His complaints concerned the events leading to his redeployment and the handling of his grievance. The last alleged discriminatory act was recorded as 19 February 2024.

The judgment recorded that the time limit expired on 8 May 2024. ACAS early conciliation began on 20 February 2025 and ended on 3 April 2025, and the Tribunal received the claim on 6 May 2025. The claim was therefore presented well outside the primary time limit and after the period following the early conciliation certificate.

Mr Black said that he had not known he could bring a claim, had not been properly advised by his trade union and had experienced periods of depression and anxiety. The Tribunal accepted that he had periods of illness but found that he also had long periods when he was fit and working. Correspondence showed that he had referred to taking legal advice in 2021, and his union had later reviewed whether he had a viable Employment Tribunal claim. The Tribunal found it difficult to accept that a conversation in early 2025 first alerted him to the possibility of making a claim.

The Tribunal accepted that the delay might have affected witnesses' recollections, though it placed little weight on that point because the grievance process had produced earlier records. Looking at the reasons for the delay and all the circumstances, it was not persuaded that extending time would be just and equitable. It declined to exercise its discretion under section 123 of the Equality Act 2010 and dismissed the disability discrimination claims without deciding their merits. No remedy was awarded or assessed.