Disability discrimination: Time limit where employee relies on employer's long-term failure to make reasonable adjustments

In Matuszowicz v Kingston Upon Hull City Council [2009] IRLR 288 CA, the Court of Appeal held that, where an employee relies on the employer's alleged continuing omission to make a reasonable adjustment, in the absence of evidence as to the date of the employer's decision, the time limit for instituting tribunal proceedings runs from the end of the period during which the employer might reasonably have been expected to effect the adjustment, unless there is an earlier inconsistent act.