Mr J Taylor-Brace v University Teaching Hospital NHS Foundation Trust — 2025

The claimant, Mr J Taylor-Brace, brought a disability discrimination complaint under sections 20-21 of the Equality Act 2010 arising from an allegation that at a meeting on 25 July 2024 he was not allowed to use captioning equipment as an adjustment. The hearing on 10 July 2025 before Employment Judge Shotter sitting alone was a preliminary hearing on jurisdiction. The Tribunal found that the claimant had volunteered to become a public governor on the respondent's Council of Governors, had been elected for a three-year term from 18 October 2023, and was unpaid, although he received expenses and some practical support when attending meetings.

The Tribunal held that the claimant was a volunteer and not an employee, worker, or office holder for Equality Act purposes. It found there was no contract of employment, no contractual obligation on the claimant to perform work, no contractual obligation on the respondent to pay him, and no mutuality of obligation. The provision of IT equipment, a lanyard, parking, meal allowance, and similar support was treated as assistance for attendance at meetings rather than remuneration. The Tribunal also relied on the statutory definitions in section 83(2) and the fact that the claimant was elected to the role rather than appointed to a remunerated office or post.

On that basis, the Tribunal held that sections 20-21 of the Equality Act 2010 did not apply and dismissed the disability discrimination claim for lack of jurisdiction. It referred to X v Mid Sussex Citizens Advice Bureau and anor, and also discussed South East Sheffield Citizens Advice Bureau v Grayson and Gilham v Ministry of Justice, but did not accept the claimant's attempt to equate his position with protected office holders. The claimant's application for a stay and/or reconsideration was refused in the interests of justice, and because the jurisdiction point disposed of the case, the strike-out and deposit application was not considered further.