Written warning was not a substantial disadvantage
In Griffiths v Secretary of State for Work and Pensions UKEAT/0372/13/JOJ, the Employment Appeal Tribunal held that a written warning given to a disabled employee who was suffering from post-viral fatigue and fibromyalgia did not place her at a substantial disadvantage, and therefore the employer did not have a duty to make reasonable adjustments to their absence management policy.
The rationale behind this decision was that Griffiths had not been treated in a different way to a non-disabled employee who was absent for the same length of time.
This decision suggests that an employer of a deaf person who is given a written warning for absences from work due to attending audiology appointments etc. may not have to make reasonable adjustments in considering whether or not to issue the written warning.