Cases8001363/2025

Claimant v Caledonian Automatic Transmissions Ltd

23 December 2025Before Employment Judge E MannionScotlandin person

Outcome

Claimant succeeds£13,649

Individual claims

Constructive Dismissalsucceeded

The tribunal found the claimant was constructively unfairly dismissed. The respondent committed a fundamental breach of the implied term of trust and confidence on 24 February 2025 by suspending the claimant without reasonable cause after a meeting lasting only seconds. The meeting on 25 February, though not itself a fundamental breach, was a final straw event showing a wholly closed mindset dismissing the claimant's concerns. The claimant resigned on 28 March citing these meetings as factors and did not affirm the breach.

Breach of Contractsucceeded

The respondent conceded a failure to provide the claimant with a statement of terms and conditions of employment under Section 1 of the Employment Rights Act 1996. The tribunal awarded three weeks' pay (£1,860) as just and equitable, recognising the wholesale failure but also that the respondent is a small organisation that has since taken steps to address the issue.

Facts

The claimant, a mechanic specialising in automatic gearboxes, was involved in an altercation on 21 February 2025 with a colleague, Mr Galloway, during which all parties, including owner Mr Tierney, swore at each other. The claimant was suspended that day and again on 24 February after a meeting lasting seconds when he did not take full responsibility. A further meeting on 25 February was pitched as a resolution meeting but the owners had a wholly closed mindset, dismissing the claimant's concerns about Mr Galloway's role in the altercation and previous threatening behaviour. The claimant went on sick leave and resigned on 28 March 2025 citing these meetings, the suspensions, bullying, and lack of a fair attempt to resolve matters.

Decision

The tribunal found the claimant was constructively unfairly dismissed. The suspension on 24 February without reasonable cause after a seconds-long meeting was a fundamental breach of trust and confidence. The closed mindset meeting on 25 February was not itself fundamental but constituted a final straw. The claimant resigned in response to these breaches and did not affirm the contract. The tribunal awarded £3,100 basic award, £8,689.22 compensatory award, and £1,860 for failure to provide written particulars. No reductions were applied for Polkey, contributory fault, or ACAS breaches.

Practical note

Suspension of an employee without reasonable cause, particularly after a perfunctory meeting where the employer has already made up their mind, can constitute a fundamental breach of trust and confidence sufficient for constructive dismissal even in a small business without formal HR processes.

Award breakdown

Basic award£3,100
Compensatory award£8,689

Award equivalent: 22.0 weeks' gross pay

Legal authorities cited

Malik v Bank of Credit and Commerce International [1998] AC 20Lochuack v London Borough of Sutton EAT 0197/14Secretary of State for Employment v John Woodrow and Sons (Builders) Ltd [1983] ICR 582 EATNorton Tool Ltd v Tewson [1972] ICR 501 NIRCSoftware 2000 Ltd v Andrews [2007] ICR 825 EATSteen v ASP Packaging Ltd [2014] ICR 56 EATNelson v BBC (No.2) [1980] ICR 110 CAFyfe v Scientific Furnishings Limited [1989] ICR 648 EATCooper Contracting Ltd v Lindsey [2016] ICR D3 EATKuehne and Nagel Ltd v Cosgrove EAT 0165/13Lawless v Print Plus EAT 0333/09Western Excavating v Sharp [1978] ICR 221Bournemouth University Higher Education Corporation v Buckland [2010] ICR 908 CALewis v Motorworld Garages Ltd [1968] ICR 157 CAOmilaju v Waltham Forest London Borough Council [2005] ICR 481 CA

Statutes

ERA 1996 s.95(1)(c)ERA 1996 s.123ERA 1996 s.1Employment Act 2002 s.38ERA 1996 s.119

Case details

Case number
8001363/2025
Decision date
23 December 2025
Hearing type
full merits
Hearing days
2
Classification
contested

Respondent

Sector
transport
Represented
Yes
Rep type
solicitor

Employment details

Role
Mechanic
Salary band
£30,000–£40,000
Service
5 years

Claimant representation

Represented
No