Jodie Satterley v Law Commission — 2025

Jodie Satterley brought a disability discrimination complaint against the Law Commission arising from an application process for a research assistant role. She said she needed reasonable adjustments for a situational judgement test because of a visual impairment and requested 25% extra time, lilac paper for materials, and permission to wear sunglasses. The tribunal recorded that the claim was limited to the Punctate Inner Choroidopathy condition and did not proceed on other conditions mentioned at the hearing.

On time limits, the tribunal accepted that the claimant was entitled to think the respondent was still dealing with adjustments until 13 February 2024, when the recruitment agency advised that no reset would be issued. It held that early conciliation had therefore been started within time. The tribunal rejected the argument that the ACAS conciliator's email meant the limitation period only started later than the certificate date, and it found no conduct extending over a period. Although the claim form was not lodged until 23 July 2024 and the claimant had technical problems submitting it earlier, the tribunal accepted that the delay was short, that the respondent identified no prejudice, and that it was just and equitable to extend time.

On disability, the tribunal found that PIC, diagnosed in December 2017, was a physical impairment for the purposes of section 6 Equality Act 2010. It accepted that the condition caused black dots in the claimant's vision, blurred vision and flashing lights, and that these effects made computer use and reading difficult and at times impossible. The tribunal found the effect was substantial because it was more than minor or trivial, and long-term because it had lasted since diagnosis. It therefore held that the claimant was a disabled person at the relevant time. No final finding was made on whether the respondent committed disability discrimination, and no remedy award was ordered in this preliminary judgment.