Respondent: Mr Samuel Scragg Maritime and Coastguard Agency v Mr Samuel Scragg Maritime and Coastguard Agency — 2025

The tribunal considered whether the Claimant was disabled at the relevant time by reason of anxiety disorder, applying s.6 and Schedule 1 of the Equality Act 2010, the statutory Guidance, and the four-stage approach discussed in Goodwin v Patent Office. The Respondent accepted that in the period from around May or June 2024 to January 2025 the impairment had a substantial adverse effect, but disputed long-term effect and recurrence before that period.

The tribunal accepted the Claimant as a credible witness and relied on a body of documentary evidence extending back to 2017. That evidence included a consultant neurologist’s letter after a 2017 accident, university support material referring to anxiety and dyslexia, a 2022 GP consultation describing worsening anxiety, nausea, avoidance of leaving the house, poor sleep and low motivation, and 2024 occupational health, NHS and fit note records referring to anxiety disorder, panic symptoms, diarrhoea, sickness, loss of concentration, weight loss and periods of unfitness for work.

On the long-term issue, the tribunal held that the Claimant had had anxiety for about fifteen years and that its effects on day-to-day activities had been intermittent but recurrent. It accepted that the 2017 accident worsened the position, and that the 2022 and 2024 records showed a not dissimilar pattern of symptoms and adverse effects. Citing paragraph 2(2) of Schedule 1 and the Guidance, the tribunal found that sporadic effects did not prevent the condition from being long-term where the substantial adverse effect was likely to recur.

The tribunal concluded that, although there was no formal diagnosis and the medical evidence was not as complete as it might have been, the material showed a likely recurrence of the substantial adverse effects. It therefore found that the Claimant was disabled at the material time by reason of anxiety disorder.