RESEARCH / VERSION 1.1 / 16 OCTOBER 2026
The origin of dependency and proof of a separate impairment
The tribunal found that the stated depressive impairment and the required effects of separate work-related stress had not been established on the evidence. It also found that the dependency had not originally arisen from medically prescribed drugs, so the regulation 3(2) exception did not apply on these facts.
| Field | Evidence |
|---|---|
| Reference period | 2019-04-29 |
| Coverage | England and Wales |
| Status | Disability-status determination |
| Source-check date | 2026-10-14 |
| Case reference | Rowley v Department for Work and Pensions, 1811127/2018 |
| Court / tribunal | Employment Tribunal (Leeds) |
| Issue | Excluded addiction; medically prescribed-drug exception; disability evidence |
| Actual disposition | Claimant found not disabled for these claims; section 15 discrimination and reasonable-adjustment claims dismissed. A separate unfair-dismissal claim was later dismissed by a judgment dated 3 February 2020. |
| Appeal / later history checked | The 29 April 2019 disability-status judgment, 3 February 2020 unfair-dismissal judgment and subsequent refusal of reconsideration have been identified in the official case family. No appellate judgment has been verified. |
| Authority level | Employment Tribunal — first instance |
| Addiction / medication scope | Dependency origin and evidence for a distinct depressive/stress impairment. |
| Targeted history check | Official case family checked 16 October 2026. No appellate judgment verified. Do not generalise the broad language in paragraph 7 into a rule excluding every separate impairment caused by addiction. |
| First-instance finding | On the records before it, dependency had not originated in medically prescribed drugs, so the regulation 3(2) exception did not apply. [Source: Paragraphs 5–9, particularly paragraph 7] |
| First-instance evidence assessment | Evidence did not establish the alleged depression or the necessary effects of separate work-related stress; the discrimination claims were dismissed. [Source: Paragraphs 9–11 and operative judgment] |
| Connected disposition | The later unfair-dismissal claim failed. [Source: Reserved judgment, 3 February 2020, operative paragraph 1] |
Paragraph-backed propositions
- On the records before it, dependency had not originated in medically prescribed drugs, so the regulation 3(2) exception did not apply. Paragraphs 5–9, particularly paragraph 7 (First-instance finding)
- Evidence did not establish the alleged depression or the necessary effects of separate work-related stress; the discrimination claims were dismissed. Paragraphs 9–11 and operative judgment (First-instance evidence assessment)
- The later unfair-dismissal claim failed. Reserved judgment, 3 February 2020, operative paragraph 1 (Connected disposition)
Interpretation limits
First-instance disability-status decision with evidential limitations recorded by the judge. It is not authority that all impairments caused by addiction are excluded. Later prescribing to treat an existing dependency was distinguished from dependency originally caused by prescribed treatment.
Sources
- HMCTS: Rowley v Department for Work and Pensions, disability judgment and reasons — Judgment and paragraphs 5–11; later judgment linked on the GOV.UK case page.
- GOV.UK case page with later decisions
- First-instance finding — Paragraphs 5–9, particularly paragraph 7
- First-instance evidence assessment — Paragraphs 9–11 and operative judgment
- Connected disposition — Reserved judgment, 3 February 2020, operative paragraph 1
- Unfair-dismissal judgment — 2020-02-03
- Reconsideration refused — Signed 26 February 2020; refuses the 19 February 2020 application to reconsider the unfair-dismissal judgment.
Cite this record
Civil Liberties Action (2026). Addiction and employment law: The origin of dependency and proof of a separate impairment. Record case-rowley-2019, version 1.1, 2026-10-16. https://cla-political-finance.copperchime4.chatgpt.site/databases/releases/2026-10-16-v1.1/records/cases/case-rowley-2019.html
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