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Universities: Knowledge of disability

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This page does not apply outside Great Britain.
Last updated 30th December 2021 (part update 3rd April 2024).

How far can a university defend an Equality Act (EqA) claim on the basis it did not know about the stammer? And what if they try to insist on medical evidence?

Summary

  • For a reasonable adjustment claim by a student, the legislation does not give the university any defence for lack of knowledge. But the Abrahart case, 2024, indicates that what the university knew or ought to have known about the student or prospective student will be relevant to the question whether it was reasonable to take a given step. Below Reasonable adjustments.
  • Whatever the legal position, if you want a reasonable adjustment, in practice it is obviously sensible to make sure the university knows about the stammer, what the difficulties are, and if possible what adjustments you would like: below In practice, it’s best to make sure university knows.
  • For a claim under s.15 EqA, discrimination arising from disability, the university has a defence if it did not know of the disability and could not reasonably be expected to know. But it need not know that the reason it treated the student unfavourably was a consequence of the stammer. Below Discrimination arising from disability.
  • As to whether a university can require medical evidence (below) before making adjustments, this too was discussed in the Abrahart case and the question seems to be what is reasonable in the circumstances. In practice, if the university does want to make further enquiries, I would suggest co-operating.
    • I suggest the university will probably be required to bear the cost (below) of any medical evidence it requires.
  • The EHRC’s Technical guidance para 7.22 points to a good practice guide published by the then DfES: Finding Out About People’s Disabilities: A Good Practice Guide for Further and Higher Education Institutions (DfES/0023/2002) (dera.ioe.ac.uk).

What this page covers

This page deals with knowledge of disability and possible evidence requirements in relation to a university’s Equality Act (EqA) duties to its own students. As regards exams or assessments, this page only includes the university’s own exams/assessments. In particular:

  • There are separate rules for professional qualification bodies.
  • The reasonable adjustment duty a university owes to non-students taking its exams has some differences from what is discussed on this page.
  • I assume (as seems to be the general view) that for the university’s own students taking its exams and assessments, it is the anticipatory reasonable adjustment duty that applies rather than the individual-based duty.

This page focuses on universities, but the position should be the same for other higher and further education providers.

Reasonable adjustments

For a student’s right to reasonable adjustments, the EqA does not set out any defence if the university is unaware of the disability (unlike DDA 1995 s.28S(3) which contained a defence). The EqA is silent on how far knowledge of the university is relevant, except for a specific provision on confidentiality requests, below.

The statutory provisions on the reasonable adjustment duty applying to universities are essentially the same as those for service providers (except for competence standards). I discuss them in relation to service providers at Knowledge of disability in anticipatory reasonable adjustment claims. At that link I suggest roughly the following approach (which seems consistent with Abrahart below), without trying to cover every situation:

  • If it is reasonable for a university to have to apply an adjustment to all students (or prospective students), even without knowing of a particular disabled person, the university can be liable even though it is not aware of the individual’s disability. Below Applying an adjustment to all students.
  • In other cases it will not be reasonable to have to make the adjustment for everyone, so that the university needs to treat the disabled student (or prospective student) differently from others, or it needs to treat differently a group (eg a seminar group) of which the disabled person is part. Here, I suggest the university should not be liable if – given the university’s (lack of) knowledge of the disability and its effects, but assuming it knew whatever it would have discovered had it made any enquiries it should reasonably have made – it was not “reasonable” for the university to have to make the adjustment. Below Treating disabled student differently.

Roughly in line with that, the High Court in University of Bristol v Abrahart, below, 2024, said that what the university “knew or ought to have known about the student or prospective student will be relevant to the question whether it was reasonable to take a given step or steps” [HC §162]. There is technically a reasonable adjustment duty whether or not the university knew of the disability, said the High Court. However what the university knew or should have known is relevant in deciding what is reasonable [§165-166]. This may be subject to future decisions by higher appeal courts, but it seems sensible to me.

Applying an adjustment to all students

A court held the UK government had to provide BSL interpretation for UK government Coronavirus press briefings, even without knowing about the particular disabled claimant: R (Rowley) v Minister for the Cabinet Office, 2021. A possible example in relation to universities and stammering:

Example: In setting up an Open Day for prospective students, a university makes sure attendees can participate and get their questions answered without having to speak in front of a group of people. The university does this even without knowing of any particular attendees with speech impairments.
See Examples of adjustments for university students>Admission>Open days.

I think there is quite a strong argument that it is reasonable for a university to have to do this (so that it is required as a reasonable adjustment), even without knowing of any particular attendee with a speech impairment. Before someone becomes a student, there is a particularly high risk that the university will not know of the disability, even if it has asked attendees in advance.

What about the following?

Example: After considering its anticipatory reasonable adjustment duty towards students with speech impairments, a university department introduces Padlet in all lectures. This tool for electronic engagement can be used by students to ask questions throughout the session, thereby improving the experience for everyone, including students with speech impairments.
Note: There are many other possible adjustments: Examples of adjustments for university students>Teaching sessions, tutorials, group work.

Is it reasonable for a university to have to introduce this or another method to allow non-oral questions (so that it is obliged to make the adjustment), even without having reason to think a particular student in that lecture has a relevant disability? That would be for a court to decide. One argument to be weighed in the balance in deciding whether universal provision of such a method is a reasonable adjustment to have to make is that many people are sensitive about their stammer, try to hide it and are reluctant to talk about it.

Treating disabled student differently

What if it is not reasonable to have to make the adjustment without knowing of a particular person’s disability? Here adjustments will presumably involve either:

  • treating people who stammer differently from others, or
  • dealing differently with a group of people – such as a seminar group – one of whom has the disability.

An example is the Abrahart case, where it was held to be a reasonable adjustment to assess a student in writing rather than orally:

University of Bristol v Abrahart, High Court, 2024
This tragic case involved a physics student, Natasha, with depression and social anxiety disorder. The university continued to seek to use oral interviews to assess her, even though she failed to attend most of them.

The university was unwilling to make significant modifications to its assessments unless Natasha got a Disability Support Summary (DSS) from the university’s Disability Services, which the university encouraged her to do. However, Natasha’s mental health disability made her unable to engage with the university’s processes and/or with strangers. This became increasingly apparent to the university. Staff were told she had self-harmed and attempted suicide.

She committed suicide in her flat on the day when the university wanted her to be part of a group giving an oral conference presentation.

The County Court held the university to be liable under the EqA, including for failure to make reasonable adjustments. The High Court upheld its decision, saying that what the university “knew or ought to have known about the student or prospective student will be relevant to the question whether it was reasonable to take a given step or steps”.

In this case, said the County Court (upheld by the High Court) the university did not have a definitive diagnosis, and the cause of her mental health issues was not fully known. However, there was never a suggestion by the university that she did not genuinely have issues with her mental health, or was anything other than genuinely unable to cope with the oral assessments. Moreover the duty to make reasonable adjustments, said the High Court, was concerned with the effect of the unversity’s provision, criterion or practice (PCP) on the disabled person of which the university was aware.

See further University of Bristol v Abrahart>Knowledge of disability: reasonable adjustments.

The EHRC Technical guidance (below) says:

7.22 An education provider should do all it can reasonably be expected to do to find out whether a student is disabled and requires reasonable adjustments. The action that it is appropriate to take to find out about a student’s disability may differ between different types of provision.

Where the adjustment requires people to be treated differently, as in the Abrahart case, I suggest – as discussed at Knowledge of disability in anticipatory reasonable adjustment claims – that a court should consider what steps it was reasonable for the university to have to take given what it knew of the disability, and also what it would have discovered had it made any enquiries it should reasonably have made. See too below Is medical evidence required?, and separate page Examples of adjustments for university students>Finding out about stammer and need for adjustments.

(Where the court is looking at the duty in an anticipatory way, it is logical for this to be part of the court considering what arrangements for adjustments it is reasonable for the university to have set up in advance. Steps to find out about students’ disabilities are part of the steps that universities should reasonably take. See Knowledge of disability in anticipatory reasonable adjustment claims>Treating differently: Anticipatory adjustments)

Example: A student who stammers needs extra time for an assessed presentation to put her on a level playing field. If this should have been evident to university staff who heard who heard the student stammering in presentations or seminars anyway, it can be argued there should be no issue of the university not knowing of the disability or the need for an adjustment. This is especially so if the disabled student has pointed out the difficulty that they face, or has suggested a reasonable solution to that difficulty.

Looking at the reasonable adjustment duty in an anticipatory way, if the university’s procedures do not trigger a requirement to take sufficient steps in these circumstances (including making any appropriate enquires), the procedures are likely to be unreasonable, and so in breach of the reasonable adjustment duty.

Looking at the duty in a more ad hoc (below) way (which seems to have been the approach in Abrahart above), again the university is likely to have sufficient knowledge here to make it reasonable for it to have to take action. Note that para 7.25 of the EHRC’s Technical guidance (below) says that once an education provider has become aware of the requirements of a particular disabled student, it might be reasonable to take steps even if it would not have been reasonable to put arrangments in place in advance.

See further below Is medical evidence required?

Note: Even if the stammer was not obvious, according to para 7.22 of the Technical Guidance quoted above an education provider should do all it can reasonably be expected to do to find out whether a student is disabled and requires reasonable adjustments. It seems right that this is part of the arrangements a university should reasonably have to set up.

In practice, it’s best to make sure university knows

Whatever the legal position, in order to try and have adjustments happen in practice, it makes sense to make sure the university knows of:

  • the disability, including by ticking any ‘disability’ box,
  • any relevant disadvantages if they are not obvious (such as giving too limited responses to questions, of which an employer was held not to have constructive knowledge in Glasson v Insolvency Service), and
  • any particular adjustments you want.

Doing this is also likely to strengthen any legal claim. Although dealing with the different rules relating to employers, where unlike with universities there is an express defence for lack of knowledge, Recruitment: Should I tell the employer I stammer? may be useful.

Bear in mind that even if you don’t think you’ll need adjustments, the unexpected may happen:

A prospective student ticked the ‘no disability’ box on his UCAS form, although he mentioned the stammer somewhere else. He stammered more in the online interview than he was expecting, as he was stressed and flustered after accidentally being left for a long time in a virtual waiting room. He felt he was unable to say what he wanted. When he complained afterwards, the univerisity said they could not make adjustments as he had not mentioned it on his application (they’d misunderstood his mention of stammering elsewhere on the form).
More: University claims it didn’t know of UCAS applicant’s stammer.

If you haven’t told the university in advance but find you are having problems in the interview, say, you could raise it with them in the interview itself (cf on employment Recruitment: Should I tell the employer I stammer?>Or consider explaining disadvantage in the actual interview, if it is getting in the way).

Confidentiality requests

There is a special statutory provision on reasonable adjustments to deal with “confidentiality requests”. This is where the disabled person or their parent has made a request for the nature or existence of the disability to be treated as confidential. In deciding whether an adjustment is reasonable, the institution (and doubtless a court) must have regard to the extent to which the adjustment is consistent with complying with the request (EqA Sch 13 para 8, discussed in Technical guidance for further and higher education para 7.28-7.30).

Example: A university student has a covert stammer. She swaps words and uses avoidance (eg often not speaking up in tutorials), so most people do not realise she has a stammer. With encouragement from a speech and language therapist she has now talked about it with the university’s disability office, and she is telling some close friends. She is willing for tutors to know, but at the moment does not want fellow students generally to know about her stammer. This may place some limitations on adjustments the university can make. However, the university should so far as possible make reasonable adjustments consistent with the student’s request for confidentiality.

If she did not want tutors to know of the stammer, the constraints on possible adjustments would likely be greater.

Ad hoc adjustments

Ad hoc reasonable adjustments by service providers, education providers etc are a difficult area technically.

On knowledge of disability as regards ad hoc adjustments, I suggested previously that perhaps the courts will decide that where an adjustment involves treating a disabled person differently, whether the service provider etc could reasonably have known of the individual’s disability is part of the general question of what steps it was reasonable for it to have to take.

This is very much what the High Court has now said in University of Bristol v Abrahart, above, 2024. The High Court said that what the university “knew or ought to have known about the student or prospective student will be relevant to the question whether it was reasonable to take a given step or steps”. Also the Abrahart case seems to have essentially taken an ad hoc approach to reasonable adjustments, looking at what it would have been reasonable for the university to do at the time, rather than considering what adjustments it should have put in place in advance.

Note that para 7.25 of the EHRC’s Technical guidance (below) says that once an education provider has become aware of the requirements of a particular disabled student, it might be reasonable to take steps even if it would not have been reasonable to put arrangments in place in advance. This seems to support the argument that there is an obligation to make ad hoc adjustments.

Discrimination arising from disability

A disabled student etc has a claim under s.15 EqA if – briefly – the university treats them unfavourably “because of something arising in consequence of” the disability, unless the university shows the unfavourable treatment was justified: see University and FE: the rules>Discrimation arising from disability and Oral assessments at university: the rules>Discrimination arising from disability.

However as discussed in detail on Knowledge of disability, the university has a defence if it did not know and could not reasonably be expected to know that the student etc has a disability. In summary:

If the university knew (or could reasonably be expected to know) of the disability, it does not need to know of the causal link between the disability and the reason for the unfavourable treatment: Knowledge of causal link with disability under s.15 EqA.

Example: In an oral assessment, a student chooses words and phrases he can say without stammering, so it sounds like he is sometimes circumlocuting, and not using technical terms he is expected to use. He is marked down for this.

The university is treating the student unfavourably “because of something arising in consequence of” the disability, under s.15 EqA. Assuming the university knows (or could reasonably be expected to know) of the disability, it is no defence that university staff did not know that the circumlocution etc resulted from the stammer.

However the university would have a defence under s.15 if it shows that marking the student down was a proportionate means of achieving a legitimate aim (justification). The possibility of assessing relevant competences in writing instead, for example, is likely to be relevant there. There would be the question of whether or how far the university’s lack of knowledge that he was circulocuting etc because of his stammer was relevant in deciding justification.

An example in the Technical Guidance illustrates the point that knowledge of the disability by one of an education provider’s employees or agents (in that capacity) is usually enough, and that the education provider does not need to realise the effects of the disability:

Example: A student has just enrolled at his local community college to do a course in local history. He has chronic heart disease and finds walking up stairs and for long distances tiring. He tells one of the administrators this when he is enrolling, but she does not realise that this will impact on his ability to go to classes at the top of the building or at the college campus on the other side of town. He is allocated to classes which are on the third floor of the college and he finds these classrooms very difficult to access. As a member of college staff is aware of his disability the college would not be able to claim that it did not know he had a disability and therefore cannot avoid liability for any discrimination arising from his disability.
Para 6.17 of the Technical guidance, 2014

Indirect discrimination

See Knowledge of disability>Indirect discrimination.

Is medical evidence required?

Evidence: In practice

In any event, if the university does want to make further enquiries, I would suggest co-operating. An example could be the university arranging for the individual to be assessed by a speech and language therapist – preferably one specialising in stammering – at the university’s expense (below Cost of medical evidence). A speech and language therapist will know much more about stammering than a GP.

In an employment context, tribunals have understandably been more likely to find against a claimant who has not co-operated with the employer’s investigation, and the same may well apply in a university context.

But at least if the stammer is evident, then actually and legally the university may well know of the disability and its relevant effects even before it investigates. So for s.15, and arguably in terms of what adjustment is “reasonable”, the university may not be justified in making adjustments conditional on expert input, except perhaps for any further hidden effects of the stammer.

Evidence: Reasonable adjustments duty

In the case of a claim for reasonable adjustments, the legislation does not give the university a defence for lack of knowledge. However, the High Court in University of Bristol v Abrahart, above, 2024, said that what the university “knew or ought to have known about the student or prospective student will be relevant to the question whether it was reasonable to take a given step or steps”. As I discuss under reasonable adjustments (above), that seems to me sensible – and something future courts may well follow – if an adjustment involves doing something differently because of the disability.

The High Court in Abrahart went on to consider the university’s argument that it didn’t need to make reasonable adjustments unless the student had obtained a “Disability Support Summary” (DSS) from the university’s Disability Service, or had produced other medical evidence. The High Court upheld the County Court decision that on the facts the university was required to make adjustments in any event. However, the High Court added that “there will no doubt be many cases where it is reasonable to verify what the disabled person says and/or to require expert evidence or recommendations so as to make well informed decisions”. It depends on what is reasonable in the circumstances. The court also made the point that what a disabled person says and/or does is evidence. See below Abrahart decision on medical evidence, particularly para 267.

So the key issue seems to be what is “reasonable”. It may often be reasonable to verify what the disabled person says and/or to require expert evidence or recommendations, but it depends on the circumstances.

We don’t know how the courts would apply this to stammering. However, particularly if effects of the disability are not evident, to be fair to other students and to maintain exam standards a university may well be able to argue they need expert input to help decide what adjustments are reasonable.

Example: A student who stammers wants extra time for an assessed oral presentation.

It may be possible for a university to argue it is reasonable for them to insist on the student being assessed by a speech and language therapist specialising in stammering, arranged and paid for by the university, to get a professional view on whether the adjustment is required. There again, university staff may well have seen the student giving presentations with a stammer and have a good idea from those – quite possibly better than the professional who may see the individual only in the clinic or on Zoom – of the need for the adjustment and how much extra time would remove the disadvantage.

Professional input may be more justified if a stammer is covert and/or if the student wants adjustments for hidden effects of the stammer, such as the student reducing or altering what they say because of the stammer.

I suggest it is unlikely to be reasonable for the university to insist on getting a letter from the student’s GP certifying what adjustments are required. Normally GPs do not know much about stammering.

In an employment context, the courts have held that an employer does not necessarily need to just take someone’s word that they have a disability: see Cox v Essex County Fire and Rescue on Employer requiring medical evidence for reasonable adjustment?>So is medical evidence required?

Abrahart decision on medical evidence

The High Court in University of Bristol v Abrahart, above, 2024, said – regarding the reasonable adjustment duty – that what the university “knew or ought to have known about the student or prospective student will be relevant to the question whether it was reasonable to take a given step or steps”

The university in Abrahart was unwilling to make significant modifications to its assessments unless the student got a Disability Support Summary (DSS) from the university’s Disability Services, which the university encouraged her to do. However, Natasha’s mental health disability made her unable to engage with the university’s processes and/or with strangers. On the reasonable adjustments claim, the High Court (bailii.org) in Abrahart said:

206. …. [The university’s] central argument was that, although the proposed adjustments could in principle have been made, due process required to be observed and there had to be sufficient evidence available to the University to justify making them.

207. The University argued, and argues, that it was therefore reasonable to require proper expert advice in the form of a DSS and/or medical evidence before taking steps that had the effect of reducing the rigour of the academic assessment. It was necessary to identify the source of Ms Abrahart’s difficulties and to receive recommendations as to the changes which should be made. This was said to be a matter of fairness to other students and necessary in order to maintain the academic integrity of the course. This was not a case in which the needs of the student might be more obvious – e.g. because they were dyslexic or a wheel chair user – and the relevant staff did not have medical or psychiatric expertise. There was always the risk of doing the wrong thing and making matters worse. In circumstances where, despite being repeatedly encouraged to do so, Ms Abrahart was not engaging with the University’s processes for obtaining such advice/evidence it was not reasonable for the University to do more than it had done.

The High Court decided that the County Court was entitled to decide here that the university was in breach of the reasonable duty. Eg see University of Bristol v Abrahart>Knowledge. Also the County Court had been critical of “the strategy of referring a student known to be unable to talk to strangers to strangers”. However the High Court added:

267. For the avoidance of doubt, the lesson of this part of the case [ie on the EqA] is not that due process and evidence are unimportant where the question of reasonable adjustments arises in this context. They are important. There will no doubt be many cases where it is reasonable to verify what the disabled person says and/or to require expert evidence or recommendations so as to make well informed decisions. A degree of procedural formality will also generally be appropriate for the reasons which the University advanced. But what a disabled person says and/or does is evidence. There may be circumstances, such as urgency and/or the severity of their condition, in which a court will be prepared to conclude that it is sufficient evidence for an educational institution to be required to take action. That was the view of the County Court on the facts of this particular case.
Emphasis added by me.

Evidence: Discrimination arising from disability (s.15)

In the case of a claim for discrimination arising from disability (above) under s.15 EqA, the university has a defence if it shows it did not know of the disability and could not reasonably be expected to know of it, as discussed at that link. For example (assuming the university cannot show justification) the student can challenge being marked down under assessment criteria relating to “fluency” or “lack of hesitation” – or otherwise due to effects of the stammer – unless the university shows it did not have that actual or constructive knowledge of the disability.

On the facts it may be evident to university staff that the stammer has a long-term and more than minor or trivial adverse effect on normal day-to-day activities. If so, presumably no further evidence is required for a s.15 claim to arise. However, it makes sense in practice to co-operate: above Evidence: In practice.

The student’s willingness to allow access to medical services was relevant in University of Bristol v Abrahart>Knowledge of disability and s.15, in holding that the university had constructive knowledge that the student’s mental condition was “long-term” and therefore a disability within the EqA. She had seen a GP at the Students’ Health Service. The High Court said the university had constructive knowledge of her disability by a certain date partly because by that point at the latest, the university could reasonably have been expected to ask the student if it could discuss the matter with the Students’ Health Service, or for her to consent to a report from this Service. The evidence strongly suggested that if she had been asked, she would have consented, and the likely duration of her condition would have been clear.

Cost of medical evidence

S.20(7) EqA makes clear that the person required to make a reasonable adjustment is not entitled to require the disabled person to pay any of the costs of complying with the duty. It might be argued this means a disabled student need not pay the costs of a report from a speech and language therapist, for example, if the university insists on one as condition of making the adjustment, even if the insistence is reasonable. However that is not clear.

In any event, for both reasonable adjustments and s.15 claims, I suggest a court is likely to find it is not reasonable for the university to insist on medical evidence for which the disabled student has to pay. It would mean the student effectively has to pay in order to get reasonable adjustments. I suggest a court is likely to find the university must pay for this.

See too Reasonable adjustments by service providers>Cost of reasonable adjustments.

Also Professional exams>Does the individual have to pay for medical evidence? – but the underlying legislation there is rather different. Even on reasonable adjustments, the legislation for professional qualifications bodies expressly talks about knowledge and what the body could reasonably be expected to know.

Technical guidance

On knowledge of the disability, the EHRC’s Technical guidance on further and higher education reads as follows:

Does the duty to make reasonable adjustments apply even if the education provider does not know that the person is disabled?

7.21 Because there is a duty to disabled students generally, it applies regardless of whether the education provider knows that a particular person is disabled or whether it currently has disabled students.

7.22 An education provider should do all it can reasonably be expected to do to find out whether a student is disabled and requires reasonable adjustments. The action that it is appropriate to take to find out about a student’s disability may differ between different types of provision.
(Guidance is available on the reasonable action an education provider should take to find out about people’s disabilities. ‘Finding Out About People’s Disabilities: A Good Practice Guide for Further and Higher Education Institutions’ (DfES/0023/2002) [link added to dera.ioe.ac.uk] England only or guidance from the Equality Challenge Unit for example www.ecu.ac.uk/publications/evidencing-equality-approaches-to-increasing-disclosure-and-take-up-of-disabled-students-allowance [seems to be no longer online].

Must education providers anticipate every barrier?

7.23 Education providers are not expected to anticipate the needs of every prospective student, but they are required to think about and take reasonable steps to overcome barriers that may impede people with different kinds of disability. For example, people with learning difficulties, mental health conditions or mobility impairments may face different types of barriers.

7.24 Disabled people are a diverse group with different requirements – for example, visually impaired people who use guide dogs will be prevented from using education facilities with a ‘no dogs’ policy, whereas visually impaired people who use white canes will not be affected by this policy. The duty will still be owed to members of both groups.

7.25 Once an education provider has become aware of the requirements of a particular disabled student it might then be reasonable for the education provider to take a particular step to meet these requirements. This is especially so where a disabled student has pointed out the difficulty that they face or has suggested a reasonable solution to that difficulty.

Example: A university anticipates that some Deaf students will require the use of British Sign Language (BSL) interpreters and ensures it has access to BSL interpreters at short notice. However, a student who arrives at the university uses American Sign Language (ASL) and had not previously notified the university of this. As soon as the university is aware of this it should consider making the necessary reasonable adjustment by seeking an ASL interpreter, even though it may not have been reasonable to have arrangements with an ASL interpreter before the student arrives.

This is largely similar to the Services Code of Practice: see Reasonable adjustments by service providers>Services Code on the “anticipatory” reasonable adjustment duty, apart from para 7.22 above which says an education provider should do all it can reasonably be expected to do to find out whether a student is disabled and requires reasonable adjustments. This compares with 7.23 of the Services Code which just says that when disabled customers request services, the service provider must already have taken all reasonable steps to ensure that they can be served. However the legal principles applying in each case are not likely to be different. I have a separate page on knowledge of disability on the part of service providers.

20th anniversary of stammeringlaw, 1999-2019