This case concerns dismissal on return from maternity leave. The respondent was in liquidation and did not participate in the proceedings. The Tribunal had to satisfy itself on the burden of proof in line with the Labour Court decision in Arturs Valpeters v Melbury Developments [2010] 21 E.L.R. 64 where it stated, “[Section 85A of the Acts] requires that the Complainant must first establish facts from which discrimination may be inferred. What those facts are will vary from case to case and there is no closed category of facts which can be relied upon. All that is required is that they be of sufficient significance to raise a presumption of discrimination. However they must be established as facts on