Cases8002952/2025

Claimant v Glasgow Prestwick Airport Limited

7 January 2026Before Employment Judge L MurphyScotlandin person

Outcome

Other

Individual claims

Automatic Unfair Dismissalnot determined

Claimant applied for interim relief under s.128 ERA claiming automatic unfair dismissal for making protected disclosures. The Tribunal refused interim relief on the basis that the claimant did not demonstrate a 'pretty good chance' of succeeding at full hearing. There were doubts over whether the communications were qualifying disclosures (whether claimant subjectively and reasonably believed they tended to show breach of legal obligation or endangerment to health/safety) and whether the principal reason for dismissal was the disclosures rather than the respondent's view that claimant was an 'insider threat'. The Tribunal made no findings in fact and the substantive claim remains to be determined.

Whistleblowingnot determined

This is the underlying basis of the automatic unfair dismissal claim. Claimant alleged he made three protected disclosures (6 Nov, 16 Nov, and 23 Nov 2025) concerning aviation security breaches. The Tribunal at interim relief stage found doubt over whether these were qualifying disclosures and whether they were the principal reason for dismissal. The substantive claim remains to be determined at a full merits hearing.

Facts

The claimant was employed as a Warehouse Operative on a fixed-term contract from 3 November 2025. Within days of starting work, he raised concerns via emails on 6 and 16 November 2025 about alleged aviation security breaches relating to unvetted agency workers handling aircraft equipment. He escalated to the Civil Aviation Authority on 23 November 2025. On 1 December 2025, after sending a letter before action alleging detriment for whistleblowing, he was summarily dismissed. The respondent stated the reason was 'some other substantial reason' due to an irreparable breakdown in trust, but later argued the claimant was identified as an 'insider threat' based on his probing questions about confidential security matters beyond his role, his limited time in post, and behavioral observations.

Decision

The Tribunal refused the application for interim relief under s.128-129 ERA 1996. The judge found that the claimant had not established a 'pretty good chance' of succeeding in his automatic unfair dismissal claim at a full hearing. There were significant doubts over whether the claimant's communications constituted qualifying protected disclosures (particularly whether he subjectively and reasonably believed they showed breach of legal obligation or endangerment), and whether the principal reason for dismissal was the disclosures rather than the respondent's insider threat concerns. The judge made no findings in fact and emphasized these were matters requiring full exploration at a final hearing.

Practical note

Interim relief applications in whistleblowing dismissals require claimants to demonstrate at a summary hearing not just that disclosures were made and dismissal followed, but that there is a 'pretty good chance' the disclosures were qualifying (reasonable belief test) and were the principal reason for dismissal, even where alternative explanations (such as security concerns) are raised by the employer.

Legal authorities cited

Blackbay Ventures Ltd v Gahir [2014] IRLR 416Kuzel v Roche Products Ltd [2008] ICR 799Korashi v Abertawe Bro Morgannwg University Local Health Board [2012] IRLR 4Kong v Gulf International Bank (UK) Ltd 2022 ICR 1513Boulding v Land Securities Trillium [2006] UKEAT/0023/06/RNTaplin v C Shippam Ltd [1978] ICR 1068London City Airport v Chacko [2013] IRLR 610His Highness Sheik Khalid Bin Saqr Al Qassim v Robinson [2018] UKEAT 0283/17Bolton School v Evans [2006] IRLR 500Arjomand-Sissan v East Sussex Healthcare NHS Trust UKEAT/0122/17

Statutes

ERA 1996 s.104ERA 1996 s.43BERA 1996 s.103AERA 1996 s.128ERA 1996 s.129

Case details

Case number
8002952/2025
Decision date
7 January 2026
Hearing type
interim relief
Hearing days
1
Classification
contested

Respondent

Sector
transport
Represented
Yes
Rep type
solicitor

Employment details

Role
Warehouse Operative
Service
1 months

Claimant representation

Represented
No