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Case law
Donelien v Liberata UK Ltd

Telling your employer you’re stressed doesn’t prove they knew you were disabled.

The ruling

“Tribunal and EAT found the employer had no constructive knowledge of her disability; her claim was dismissed.”

Your employer's duty to make reasonable adjustments only bites once they know, or reasonably should know, that you are disabled. Vague or shifting descriptions of your symptoms can mean a tribunal finds they never had enough to go on.

  • Push for an Occupational Health referral that directly asks whether your condition meets the legal definition of disability and how long it is expected to last, not just whether you are fit for work.
  • Keep your own description of your condition consistent and specific across meetings, letters, and sick notes, rather than switching between different labels for what may be one underlying condition.
  • If you are facing dismissal or discipline and believe a disability is part of the picture, get advice as early as possible, before the process concludes.
Read the full case

The situation

An employee worked as a court officer for almost 11 years before being dismissed for poor attendance. In her final year she was absent on 20 separate occasions, around 128 days in total, for a mix of reasons including stress, hypertension, and ordinary illnesses like flu and colds. Her employer referred her to Occupational Health and held return-to-work meetings, but the picture they were given kept shifting. Sometimes it was stress, sometimes hypertension, sometimes an unrelated infection. She was later found, in a separate ruling, to have in fact been disabled throughout that period.

What the tribunal found

The tribunal dismissed her disability discrimination claim. The tribunal held that, at the relevant time, nothing available to her employer would reasonably have flagged her as disabled. The employer had done what it reasonably could. It referred her to Occupational Health, met with her, and asked her GP for information. None of that advice confirmed she met the legal definition of disability, and many of her absences were put down to conditions, like flu and colds, that had nothing to do with any long-term impairment. On appeal, the Employment Appeal Tribunal upheld the finding. It was open to the tribunal on the evidence, and involved no error of law.

Full citation

Donelien v Liberata UK Ltd. UKEAT/0297/14/JOJ. Employment Appeal Tribunal. 16 December 2014.

Last reviewed 16 July 2026