Case Update: Robert Watson v Roke Manor Research Limited
In a recent employment tribunal case, a software engineer named Robert Watson succeeded in a disability discrimination claim against his former employer, Roke Manor Research, a Hampshire-based technology consultancy. Watson, who has a diagnosis of Attention Deficit Hyperactivity Disorder (ADHD), argued that he had been subjected to a hostile working environment due to his condition and that his employer had failed in its duty to make reasonable adjustments.
The crux of the claim involved the behaviour of Watson’s line manager, referred to in tribunal papers as “DT”, who allegedly responded to Watson’s ADHD-related conduct with regular sighs and exaggerated exhalations. These nonverbal cues, although subtle, were interpreted by the tribunal as displays of irritation and disapproval directed toward Watson’s neurodivergent traits, including his tendency to speak at length and repeat himself. The tribunal found that such behaviour contributed to a degrading and humiliating working environment, which amounted to unlawful discrimination arising from disability.
Watson had been hired in a hybrid role combining software engineering with public engagement, yet he was later removed from the outward-facing aspects of his job without consultation. The tribunal determined that this adjustment was not only implemented without proper process but also constituted a failure to accommodate his disability. Although the employer attempted to attribute the breakdown of the employment relationship to general communication difficulties, the tribunal accepted that Watson’s treatment was influenced by a poor understanding of his neurodivergent condition and a lack of reasonable support. Ultimately, Watson was awarded compensation for injury to feelings.
Key Takeaways
For employers, this case is a sharp reminder that discrimination can arise not only from overt acts or decisions but also from subtle interpersonal behaviours that signal exclusion or disapproval. Nonverbal conduct, such as sighing, eye-rolling, or dismissive gestures, can—when persistent and directed at traits associated with a disability—form part of a discriminatory pattern. The legal threshold for harassment and discrimination under the Equality Act 2010 does not require intent to cause harm; it focuses on the effect of the conduct and whether it creates a hostile, degrading, or humiliating environment.
This decision also highlights the litigation risks associated with failing to make reasonable adjustments. Employers must not only take seriously their duty to identify and implement support measures for disabled employees but also ensure that any changes to roles or responsibilities are discussed transparently and justified through objective reasoning.
Moreover, managers need training not only in legal compliance but in interpersonal awareness—particularly in relation to neurodivergence. Misunderstandings, especially in high-pressure environments, can quickly evolve into legal liabilities if they are not handled with sensitivity and professionalism.
Ultimately, the case illustrates how workplace culture, management behaviour, and a failure to engage meaningfully with neurodivergent staff can expose employers to reputational damage and significant compensation awards. Proactive education, regular reviews of reasonable adjustments, and an inclusive approach to communication are essential steps in reducing the risk of tribunal claims and fostering a genuinely supportive workplace.
