Decision: An employer had not failed to make reasonable adjustments in circumstances where those adjustments related to the disability of an employee’s daughter, rather than the employee herself.  The obligation to make reasonable adjustments only arises in the context of the employment relationship between employer and employee.

Impact: This is an important case which clarifies that non-disabled employees will normally not be entitled to reasonable adjustments based upon their association with a disabled person.  The situation is different, however, in relation to direct discrimination and harassment, where claims of associative discrimination can be brought.

Hainsworth v Ministry of Defence