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Salford NHS Primary Care Trust v Smith - To be a "reasonable adjustment", step must remove substantial disadvantage of PCP [2011] EAT

In a disability discrimination claim, a proposed "reasonable adjustment" is only such if it will prevent the relevant "provision criterion or practice" placing the disabled person at a substantial disadvantage. Therefore consultations, trials, and exploratory investigations - although they may prove to be the precursors to reasonable adjustments - do not in themselves qualify.

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