An employee does not need to show a very strong causal connection between disability and unfavourable treatment to bring a "discrimination arising from a disability" claim. However, as the EAT has made clear in iForce Ltd v Wood, there still has to be some link between the two. An employee's mistaken belief that new working practices would have a negative effect on her osteoarthritis did not arise "in consequence of her disability" so her disability discrimination claim could not succeed.
Mrs Wood worked in a warehouse. She suffered from osteoarthritis and various adjustments had been made to her role to accommodate her disability. In 2016 working practices were changed to improve productivity, which sometimes required her to work by the warehouse doors. She refused to do so, believing that the temperature by the doors would be colder and that this would exacerbate her condition. The employer investigated the concern and found that there were no material differences in temperature in different parts of the warehouse. When the employee continued to refuse to work by the doors she was given a written warning and claimed that this was discrimination arising from a disability.
The tribunal found that Mrs Wood's refusal to work arose in consequence of her belief that the instruction would affect her disability and upheld her claim. However, the EAT overturned the decision. To succeed in her claim, Mrs Wood had to show that the "something" that led to unfavourable treatment (here her refusal to work) arose in consequence of her disability. It was the employee's mistaken belief that caused her to refuse to work. But she did not hold the mistaken belief that conditions were colder by the door because of something arising from her disability. The absence of a causal link between the disability and the belief was fatal to her case.