0/12 RA + defence admission + Cohen remark = triple proof.
Systematic discrimination arising from disability (s.15), failure to make reasonable adjustments (s.20), discrimination in provision of services (s.29), and breach of Public Sector Equality Duty (s.149) across all proceedings.
Equality Act 2010 ss.15, 20, 29, 149; Galo v Bombardier [2016] NICA 25
What the opponent will argue, and why they are wrong.
Applicant's disability was not known to the court.
HMCTS allocated RA Ref 67862925 on file. Dr Woolley report provided. ADHD disclosed in multiple emails. MHCM certificate provided (which exists BECAUSE of mental health conditions). The court KNEW. Galo v Bombardier: wholesale failure to adjust requires setting aside.
EA 2010 duties apply to service providers, not the court acting in its judicial capacity.
HMCTS is a service provider under EA 2010 s.29. The judiciary is subject to s.149 PSED. PD 1A explicitly requires courts to adapt procedures for disabled parties. The Equal Treatment Bench Book (ETBB May 2025) provides detailed guidance. Both service provision and judicial functions are covered.
Formal admission binding under CPR 14.1(5). Signed by Zulfikar Virani under Statement of Truth.
Logged and scheduled. 12 requests across 6 courts, 7 judges. 0 granted.
Formal admission binding under CPR 14: 'It is admitted that adjustments were not made for him.'
Defence admits Michael warned of police/harassment complaint on 17 Feb 2023 AND admits two further lockouts on 27 Apr and 20 May 2023.
Fallback: Rely on JR-19 (0/12 RAs), JR-20 (no PSED), and JR-17 (Article 14) for EA 2010 claims.
Independence: Partially dependent on other grounds succeeding.