Claimant won Employment Tribunal · 7 July 2023

Missing address on ET1 form: tribunal extends time limit for unfair dismissal claim

A former employee of Lloyds Bank who omitted her full postal address from an online ET1 form had her unfair dismissal claim accepted out of time after the tribunal ruled it was not reasonably practicable to present it correctly.

1 min read · Last updated 18 May 2026

Case details

Key facts

  • The claimant submitted her ET1 on 10 September 2022, about 20 days before the deadline.
  • The claimant did not provide her full postal address on the ET1, using a default postcode instead.
  • The claimant had concerns about post security in her shared house and preferred email communication.
  • The claim was initially accepted by administrative staff, but later rejected due to the missing address.
  • The claimant provided her address on 28 October 2022 after being told it was required.
  • Employment Judge Curtis reconsidered and accepted the claim with effect from 28 October 2022.

Timeline

  1. Effective date of termination (disputed)

    The claimant's employment ended, with dispute over whether the date was 25 or 27 May 2022.

  2. ACAS Early Conciliation started

    The claimant engaged in ACAS Early Conciliation, which lasted until 16 August 2022.

  3. ET1 submitted

    The claimant submitted her unfair dismissal claim online, but omitted her full postal address.

  4. Fox Court requested address

    Mrs. Ambreen Ali emailed the claimant asking for her full postal address.

  5. Claimant replied, email confirmed

    The claimant asked if email communication was possible; Mrs. Ali confirmed email was fine.

  6. Claim accepted

    The claimant was informed her claim had been accepted and it was served on the respondent.

  7. Respondent's response

    The respondent submitted a substantive response without raising the address issue.

  8. Tribunal staff requested address again

    An administrative staff member emailed the claimant stating the claim could not proceed without an address.

  9. Claimant provided address

    The claimant provided her full postal address, the same as on the ACAS certificate.

  10. Claim rejected by Judge Wright

    Employment Judge Wright directed rejection due to the missing address on the ET1.

  11. Rejection notified

    The claimant was emailed that her claim had been rejected.

  12. Reconsideration requested

    The claimant requested reconsideration of the rejection.

  13. Reconsideration granted

    Employment Judge Curtis accepted the claim with effect from 28 October 2022.

  14. Preliminary hearing on time limit

    The tribunal heard whether the claim was presented in time.

  15. Judgment issued

    Employment Judge Cawthray ruled it was not reasonably practicable to present the claim in time and it was presented within a reasonable further period.

The outcome

The tribunal ruled in favour of the former employee, allowing her claim to proceed despite being presented out of time.

The key reason was that the claimant had used a default postcode in the online ET1 form because she had concerns about post security and believed the form indicated that a default postcode was acceptable. The tribunal accepted that this was an understandable mistake and that it was not reasonably practicable for her to have presented the claim correctly within the original time limit.

No compensation was awarded at this preliminary stage – the decision only concerned whether the claim could proceed.

Lessons & takeaways

  • Always provide your full postal address on an ET1 claim form, even if you prefer email communication – the tribunal requires a physical address for service.
  • If you have concerns about post security, you can ask the tribunal to use email as the primary method, but you must still provide a postal address.
  • If your claim is rejected for a procedural error, you can request reconsideration – the tribunal may accept the claim as presented on the date you corrected the error.
  • The time limit for unfair dismissal claims is strict, but if it was not reasonably practicable to meet it, the tribunal can extend the deadline if you acted promptly.

This case shows how a seemingly minor administrative error – omitting a full postal address from an online tribunal claim form – can jeopardise an entire unfair dismissal claim. The former employee, who had worked for Lloyds Bank, submitted her ET1 about 20 days before the deadline but used a default postcode instead of her actual address because she lived in a shared house and had concerns about post being opened by housemates.

What went wrong

The online form contained a box that the claimant interpreted as allowing a default postcode if she could not provide an address. She ticked the box for email communication and submitted the claim. Tribunal staff initially accepted the claim, but later rejected it because the address was missing. By the time she provided her full address – the same one that appeared on her ACAS early conciliation certificate – the statutory time limit had passed.

Why the tribunal allowed the claim to proceed

Employment Judge Cawthray accepted that the claimant had made an honest mistake based on the information available in the online form. The tribunal noted that the respondent had not raised the address issue in its response, and that the claimant had acted promptly once she realised the address was required. The judge ruled that it was not reasonably practicable for the claim to have been presented within the original time limit, and that the claim was presented within a further reasonable period.

What this means for similar claims

This case is a reminder that procedural requirements in employment tribunals are taken seriously, but the tribunal will consider the circumstances of each case. Claimants who make genuine errors when completing forms – especially if they are unrepresented – may still be able to proceed if they act quickly to correct the mistake. However, the safest approach is to provide all requested information, including a full postal address, even if you prefer email communication.

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