Employment Judge Liz OrdIn person for claimantIan Steel (instructed by solicitor) for respondentDate 26 November 2025
REASONS
[1]This was an application by the respondent under rule 38 of the Employment Tribunal Procedure Rules 2024 to strike out the claimant’s case on the grounds that the manner in which the proceedings have been conducted by the claimant has been unreasonable and vexatious.[2]The claimant wishes to be known as “gloria”; all lower case with no title.
Background
[3]The claimant has sent a voluminous catalogue of lengthy, abusive correspondence to the respondent and its solicitor, Ian Steel, and to the tribunal, the thrust of which I have attempted to capture below.[4]After receiving the response to her claim, the claimant made an application to strike it out on 23 September 2024. She alleged that Ian Steel had knowingly and intentionally sent her false documents in bad faith to cause her loss, which was against the morality of law.[5]On 11 October the claimant wrote to the tribunal saying the respondent was not acting with honour or good faith and she requested that judgment be entered for the amount claimed within three days.[6]The claimant did not accept that Mr Steel was properly acting for the respondent and demanded proof. She objected to him acting and refused to communicate with him, directing her correspondence to the respondent directly. EJ Corrigan considered this objection and dismissed it on 14 October 2024. Despite this, the claimant continued writing to the respondent directly.[7]On 23 October, in refusing the claimant’s strike out application for lack of any basis, EJ Corrigan commented that the claimant’s allegation that the response was a fraudulent document was very serious.[8]On 24 October the claimant wrote a 27 page aggressive letter to the tribunal containing many misguided demands and unreasonable comments, and naming tribunal clerks. In it she objected to the tribunal’s letter of 23 October on the grounds of irregularity, and made irrational comments about tribunal correspondence being sent in bad faith. She demanded judgment for the claimant not later than 1 November 2024, and again challenged the lawful standing of the respondent’s solicitor, demanding to know why the tribunal was writing to him. She went on to make various other incomprehensible references to deception and fraud, and indicated bias on the part of the tribunal.[9]On 25 October Mr Steel wrote to the claimant pointing out that her objection to him acting had been dismissed and that they should now cooperate with each other, as expected by the tribunal. He warned the claimant that if she continued to communicate with his client directly it could be considered unreasonable behaviour and that he might make a strike out application.[10]On 28 October the claimant sent a subject access request to the British Printing Industries Federation (BPIF), for whom Mr Steel is a trustee and legal advisor.[11]Mr Steel responded with a polite, professional reply on 4 November explaining that the BPIF was a Trade Association for the Printing Industry that provided various services for its members, including legal advice and representation, and that he was the solicitor acting for the respondent, who was a member of the BPIF. He advised her that any personal data BPIF held was that provided by the respondent for the sole purposes of proceedings in the employment tribunal. He then went on to respond courteously to ten requests the claimant had made.[12]However, the claimant continued to object to Mr Steel acting and she refused to receive any correspondence from him. Consequently, she reported him to the police for harassment, on the basis he had sent the above mentioned 4 November letter by post via Royal Mail and a hard copy of a hearing bundle for an upcoming preliminary hearing.[13]On 11 November the claimant wrote another long threatening letter addressed to various directors and office holders of the BPIF and Mr Steel. She referred to the recipients as “Respondents”, “Libellees”, and “Trustees”. Much of the letter is incomprehensible and again makes allegations of fraud, amongst other things.[14]The letter accused Mr Steel of acting illegally and committing criminal torts, which she would use as evidence in further action. She accused him of trespass by sending her correspondence dated 8th November 2024 via Royal Mail using postage stamps, which she would not accept and was returning. She ordered him to stop his unwanted actions against her and her private property or face criminal charges and substantial damages.[15]Also on 11 November, the claimant returned correspondence from the employment tribunal, sent to her at her correct address and showing her correct name, on which she wrote these comments “false details”, “malicious communication”, “offer to contract not accepted and no consent is given”.[16]On 12 November EJ Leith wrote to the claimant informing her that it was not up to her to “accept” matters she received from the tribunal, nor to object to the respondent’s ET3 and Grounds of Resistance. He said that the claimant’s letter of 24 October 2024 was lengthy and repetitious. Specifically he referred to the letter taking issue at some length with how the tribunal formatted the claimant’s name and used capital letters.[17]EJ Leith went on to record that the letter contained entirely incomprehensible allegations of fraud and bad faith against the respondent and numerous citations of international decisions which had no relevance to the Employment Tribunal. He stated that the letter was threatening in tone, including threatening personal liability against the officers of the respondent, the respondent’s representative, and the tribunal itself.[18]The judge warned the claimant of the tribunal’s powers to strike out a claim if, amongst other things, the manner in which proceedings were conducted were scandalous, unreasonable or vexatious. He said that further correspondence in the same vein as the letter of 24 October 2024 might lead the tribunal to conclude that she was conducting the proceedings in an unreasonable and/or vexatious manner.[19]On 10 January 2025 the tribunal wrote to the claimant ordering her to send all future correspondence in these proceedings to the respondent’s named representative, identified in the response form as Mr Ian Steel, and it set out his professional postal address and his email address.[20]Also on 10 January EJ Hart wrote to the claimant about her refusal to “accept” tribunal correspondence. EJ Hart pointed out that the correspondence had been sent to the address she had provided in her claim form and there was no procedural error. EJ Hart addressed the claimant’s application for a default judgment and refused it. She reminded the claimant that she was at risk of the tribunal concluding that she was conducting the proceedings in an unreasonable and/or vexatious manner. This meant she was at risk of her claim being struck out.[21]On 14 January, despite EJ Hart’s letter of 10 January, the claimant sent to the tribunal “Notice of Application for Default Judgment for the Claimant” “To be placed before the President of the Tribunal within fourteen (14) days from receipt…” It continued “Offer to contract from the tribunal showing 10 January 2025 …unopened and returned …”. In it she made numerous unintelligible demands, and again named a tribunal clerk and accused them of falsehood and causing harm.[22]On 25 July 2025 there was a preliminary hearing before EJ Lumby, at the start of which the claimant took some considerable time to again object to Mr Steel acting. In order to break the impasse, Mr Steel agreed to send her a letter from the respondent confirming Mr Steel was acting, which he did immediately. Mr Steel also requested a preliminary hearing for strike out of the claim. EJ Lumby listed today’s hearing.[23]The claimant responded to Mr Steel the same day saying she had received “yet another unsolicited, false, and misleading email sent by way of trespass and harassment from Ian Steel today [Friday 25 July 2025 at 10:50am], the contents of which are noted and, (like all previous emails from Ian Steel) are not accepted and are rejected due to the contents of all the emails being false and sent in bad faith …” She continued “I demand that you, Ian Steel, cease and desist from contacting me directly…”[24]On 14 August, the claimant wrote to EJ Lumby requesting the case management order of 25 July. The letter started with a warning saying “Do not ignore – Time Sensitive Document, amongst other things (this was a demand she regularly put on her correspondence).[25]On 3 September, the claimant wrote again to EJ Lumby, starting her letter with the same warning and raising a procedural objection concerning “serious irregularities in the respondent’s representation and the integrity of documents submitted to the tribunal by Ian Steel.”[26]On 11 September the claimant made a “Request to Strike-Out Rebuttal” amongst other things, in an aggressive manner. Again, she challenged the authority of Mr Steel to act for the respondent. She accused him of being obstructive from the beginning for repeatedly refusing to provide documentary evidence of his authority to act and suggested his email correspondence had an inflammatory tone. She failed to identify the correspondence she was referring to.[27]On 6 October the claimant made another application concerning the “identity, authority, and procedural standing of the individual and entities purporting to act on behalf of the respondent.”[28]On 15 October the claimant made a counter application to strike out the ET3 and Grounds of Response.[29]At the start of today’s preliminary hearing to hear the respondent’s application for strike out, I noted several applications that were also before me from the claimant and indicated that I would hear the strike out application first. I explained that I would not hear her application regarding Mr Steel’s authority to act, as it had already been dealt with by the tribunal and it was a matter for the respondent to choose who they instructed. I informed her that she was not entitled to see authorisation of acting, albeit the respondent had voluntarily provided this already, confirming that Ian Steel was their representative. I told the claimant that that was the end of the matter. The claimant responded by saying this was biased.
Law
[30]Rule 38 of the Employment Tribunal Procedure Rules 2024 sets out the tests for strike out. Relevantly it states: (1) The Tribunal may, on its own initiative or on the application of a party, strike out all or part of a claim, response or reply on any of the following grounds - (a) that it is scandalous or vexatious or has no reasonable prospect of success; (b) that the manner in which proceedings have been conducted by or on behalf of the claimant or the respondent (as the case may be) has been scandalous, unreasonable or vexatious; (c) for non-compliance with any of these Rules or with an order of the Tribunal; (d) that it has not been actively pursued; (e) that the Tribunal considers that it is no longer possible to have a fair hearing in respect of the claim, response or reply (or the part to be struck out).[31]In HM Prison Service v Dolby [2003] IRLR, 694 and Hassan v Tesco Stores Ltd UKEAT/0098/16 the EAT held that the striking out process requires a two-stage test. The first stage involves a finding that one of the specified grounds for striking out has been established; and if it has, the second stage requires the tribunal to decide as a matter of discretion whether to strike out the claim. In Hassan Lady Wise stated that the second stage is important as it is “a fundamental cross check to avoid the bringing to an end prematurely of a claim that may yet have merit.”
Conclusion
[32]There is no doubt, based on the background set out above, that the claimant has conducted proceedings in an unreasonable and vexatious manner, which is a ground for strike out. I have taken a step back and considered the circumstances in the round. Using my discretion, I conclude that strike out is a proportionate response to the claimant’s behaviour. I therefore strike out the entirety of the claimant’s claims. Approved by: RECONSIDERATION JUDGMENT The claimant’s application dated 16 December 2025 for reconsideration of the strike out judgment and order refusing anonymity and restricted disclosure, both sent to the parties on 12 December 2025, is refused.
Conclusion
[1]Employment Judge Ord apologises for the delay in producing this judgment, which was caused by her not receiving the application until 6 March 2026.[2]By Rule 68 of the Employment Tribunal’s Rules of Procedure 2024, the Employment Tribunal may, either on its own initiative or on the application of a party, reconsider any judgment where it is necessary in the interests of justice to do so. On reconsideration, the judgment may be confirmed, varied or revoked.[3]There is no provision in the Procedure Rules for reconsideration of an order. On this basis, the application for reconsideration of the order refusing anonymity and restricted disclosure, is refused.[4]The judgment will only be reconsidered where it is necessary in the interests of justice to do so. This allows the Employment Tribunal a broad discretion, which must be exercised judicially. This means having regard not only to the interests of the party seeking the reconsideration but also the interests of the other party to the litigation and to the public interest requirement that there should, so far as possible, be finality of litigation. Reconsiderations are therefore best seen as limited exceptions to the general rule that employment tribunal decisions should not be reopened and relitigated.[5]If there is no reasonable prospect of the judgment being varied or revoked, the application must be refused.[6]The tribunal properly considered the evidence before it at the hearing and came Case No: 6006814/2024 to the conclusion, based on the evidence, that the claimant had conducted the proceedings in an unreasonable and vexatious manner. Using its discretion it concluded that strike out was a proportionate response to the claimant’s behaviour. The reasons for this are adequately set out in the judgment.[7]There were no procedural irregularities in the proceedings, as suggested by the claimant. The respondent’s representative was properly appointed and conducted matters in a professional manner.[8]There was no bias or predetermination. The hearing was conducted with an open mind and the claimant’s applications were dealt with. The claimant was given full opportunity to participate. There was no unfairness or breach of natural justice, as suggested.[9]A party’s disagreement with the tribunal’s judgment is not a good reason to reconsider.[10]There is nothing in the claimant’s application which justifies a reconsideration.[11]Taking account of the overriding objective of dealing with cases justly and fairly, I conclude that it is not necessary in the interests of justice to reconsider the original judgment as there is no reasonable prospect of it being varied or revoked.