Mr John-Paul Pryce v Accountant in Bankruptcy — 2023

The claimant brought disability discrimination and reasonable adjustment complaints, with the adjustment contended for being that he should be allowed to work entirely from home. This hearing was directed only to the preliminary question whether he was disabled within section 6 of the Equality Act 2010. The tribunal heard evidence from the claimant and his partner, and considered occupational health material and GP correspondence dated 21 December 2022, 1 March 2023, 14 August 2023 and 2 October 2023.

The tribunal accepted the claimant as a credible and reliable witness. It found that he had developed an entrenched phobia involving fear of being in enclosed or crowded places and fear of germs and contamination, that his social life had become very limited, and that he avoided indoor spaces, hospitals and close contact with others. Although the occupational health report had suggested that he was unlikely to be disabled, the tribunal considered the later GP letters and the factual evidence sufficient to show a mental impairment with a substantial and long-term adverse effect on normal day-to-day activities. It applied section 6 of the Equality Act 2010, the statutory guidance, the Goodwin v Patent Office questions, and the authorities cited on normal day-to-day activities and mental impairment.

The tribunal therefore held that the claimant was disabled for Equality Act purposes. The reasons repeatedly describe the worsening of the condition from March 2020 and after the pandemic, although the final sentence of the judgment states that he was disabled "from March 2000", which appears inconsistent with the rest of the reasons. As this was a preliminary hearing, the tribunal did not decide whether the requested home-working adjustment was reasonable or determine the underlying discrimination claim on its merits.