Claimant v PriceWaterhouseCooper Services Ltd — 2025

At the preliminary hearing on 11 and 17 June 2025, the tribunal considered whether Mr F George was a disabled person within section 6 of the Equality Act 2010 in relation to Burnout and Other Specified Trauma- and Stressor-Related Disorder. The respondent had already conceded disability in relation to ASD and ADHD, so those conditions were not in issue. The tribunal heard from the claimant, Dr Sian Armstrong, and Dr Christopher Gordon Salt, and had before it GP and occupational health records together with Dr Armstrong's report.

The tribunal held that Burnout was not itself a condition or impairment, but rather a consequence or symptom of other experiences. It therefore could not amount to a disability within section 6. On the asserted Trauma Disorder, the tribunal did not accept the claimant's case that it existed from August 2020. Greater weight was placed on the contemporaneous GP and occupational health records, and the judge treated Dr Armstrong's opinion with reserve because it depended heavily on the claimant's self-report and did not have the occupational health records.

The tribunal found that the claimant's mental health difficulties were not made out on the evidence before February 2022, but that by 23 February 2022 he had low mood, disrupted sleep and reduced energy, and had started medication. It held that from that date the condition described as Other Specified Trauma- and Stressor-Related Disorder amounted to a mental impairment with a substantial, long-term adverse effect on normal day-to-day activities. The tribunal made no finding that the condition was caused by the respondent's actions, and the proceedings were sisted after the preliminary issue was decided.