The Employment Appeal Tribunal in Doran v the Department of Work and Pensions held that there was no duty to make reasonable workplace adjustments when the employee was certificated as unfit for any work and there was no indication of a return to work date.

Another indication of how a seemingly unhelpful GP Fitnote (or OH report) can have considerable employment implications.

See: http://www.bailii.org/uk/cases/UKEAT/2014/0017_14_1411.html