UK: Disability - duty to make reasonable adjustments

Recent EAT rulings have established that:

• it is not a reasonable adjustment to give a disabled employee on sick leave a career sabbatical, nor to provide rehabilitative non-productive work for the employee to do for a period. Reasonable adjustments for a disabled employee on sick leave are primarily concerned with helping them return to work. Steps such as consultations and trial periods are useful in ascertaining what reasonable adjustments can be made, but are not themselves adjustments which employers are obliged to make. (Salford NHS Primary Care Trust v Smith, EAT)
• if there is an adjustment which has a prospect of removing a disabled employee's disadvantage, it may amount to a reasonable adjustment that an employer should make. The fact that there is not a "good or real" prospect of success does not automatically make the adjustment unreasonable. This ruling slightly lowers the threshold for showing that an adjustment would be reasonable. (Leeds Teaching Hospital v Foster, EAT)
• whether an adjustment is reasonable in light of its cost is a matter of judgement for the tribunal (making their rulings difficult to appeal).  A tribunal can take into account a variety of factors such as the size of any budget dedicated to reasonable adjustments (though this cannot be conclusive), what the employer has spent in comparable situations (in this case, an education allowance per employee's child to assist relocation abroad), what other employers are prepared to spend, and any collective agreement or other indication of the level of expenditure regarded as appropriate by representative organisations.  (Cordell v FCO, EAT)