Steedman v East Lothian Council [2026] EAT 142
Second appeal arising from alleged failure to make reasonable adjustments
The claimant, employed by East Lothian Council from 2001, was dismissed for capability in October 2017. An ET in 2020 upheld her claims, including failure to make reasonable adjustments. On appeal, the unfair dismissal and discrimination arising from disability findings were overturned and remitted, but the reasonable adjustments finding stood. A second tribunal dismissed those remitted claims and awarded £15,250 for injury to feelings and psychiatric injury, finding the adjustment was a transfer within her team between 12 October and 29 November 2016, and no financial loss flowed. She appealed, alleging impermissible recasting of earlier findings and inadequate compensation.
Lady Poole dismissed the appeal. The ET had not erred in law; had permissibly interpreted the earlier tribunal’s findings about reasonable adjustment; had properly made an award in respect of injury to feelings and psychiatric injury, and was entitled to conclude on the facts found by it that no financial loss flowed from the failure to make reasonable adjustments.
https://www.gov.uk/employment-appeal-tribunal-decisions/steedman-v-east-lothian-council-2026-eat-142
Published: 04/11/2026 09:57