Cases8001235/2025

Claimant v Fueltone Limited (In Liquidation)

7 January 2026Before Employment Judge M RobisonScotlandremote video

Outcome

Claimant fails

Individual claims

Redundancy Payfailed

The tribunal found that although the claimant did not resign by words, her conduct in requesting a P45 amounted to a resignation. The creation and furnishing of a P45 with a leaving date of 17 January 2025 was definitive evidence of termination of the employment contract by resignation, not dismissal. Therefore the claimant was not entitled to a redundancy payment.

Facts

The claimant worked as an administration manager for a fuel additive company from October 2019. On 19 December 2024, she was told the company would go into liquidation and not to return to work. As a single parent of three, she secured part-time employment with Enerion starting 20 January 2025. She requested her P45 for the new employer's payroll, and a P45 was issued showing a leaving date of 17 January 2025. The company went into liquidation in February 2025 and the Insolvency Service rejected her redundancy payment claim on the basis she had resigned.

Decision

The tribunal dismissed the redundancy payment claim, finding that although the claimant never stated she was resigning orally or in writing, her conduct in requesting a P45 amounted to a resignation. The tribunal held that while requesting a P45 is ambiguous, the actual creation and furnishing of a P45 with a specific leaving date is definitive evidence of termination by resignation, not dismissal.

Practical note

Requesting and accepting a P45 from an employer can constitute resignation by conduct, even in the absence of express words of resignation and even where the employee subjectively believed they remained employed.

Legal authorities cited

Bates v Brit European Transport Ltd 309/94Johnston v Monty Smith Garages Ltd EAT/657/79Edwards v Surrey Police [1999] IRLR 456

Statutes

ERA 1996 s.163ERA 1996 s.135ERA 1996 s.145ERA 1996 s.162ERA 1996 s.164

Case details

Case number
8001235/2025
Decision date
7 January 2026
Hearing type
full merits
Hearing days
1
Classification
contested

Respondent

Sector
energy
Represented
No

Employment details

Role
administration manager
Service
5 years

Claimant representation

Represented
No