Cases2206663/2020

Claimant v Harrods Ltd

19 December 2025Before Employment Judge A M SnelsonLondon Centralin person

Outcome

Claimant fails

Individual claims

Unfair Dismissalfailed

The tribunal found that the reason for dismissal was genuine redundancy following a business reorganisation. The redundancy process was fair, with reasonable selection criteria applied objectively. The claimant lost a tie-break interview by one point, and there was no evidence the redundancy was a sham or influenced by any ulterior motive.

Automatic Unfair Dismissalfailed

The tribunal found that the claimant was not 'designated' to carry out health and safety activities as required by s100(1)(a) ERA 1996. His health and safety duties were part of his ordinary job role, not a special designation beyond normal duties. Furthermore, even if designated, health and safety activities played no part in the dismissal decision.

Whistleblowingfailed

While the tribunal accepted that some of the claimant's communications amounted to protected disclosures, it found that such disclosures were not the reason, or even a contributory reason, for the dismissal. The sole reason for dismissal was redundancy following a genuine business reorganisation.

Facts

The claimant was employed by Harrods as an Out of Hours Duty Manager from December 2017 until dismissed for redundancy on 4 October 2020, earning approximately £50,000 annually. Following the Covid-19 pandemic which closed the Knightsbridge store and resulted in £425 million lost sales, Harrods implemented a major reorganisation affecting approximately 700 employees. The claimant's department reduced Out of Hours Duty Managers from three to two positions. In a selection process using five objective criteria, the claimant tied with the other Duty Manager, Mr Sullivan, at 12 points each. A tie-break interview resulted in Mr Sullivan scoring one point higher. The claimant was placed at risk on 30 June 2020, underwent collective and individual consultation, and was dismissed effective 4 October 2020 after an unsuccessful appeal.

Decision

The tribunal dismissed all claims. It found the redundancy was genuine, arising from a demonstrable business need following pandemic-related financial losses. The selection process was fair, using reasonable objective criteria and a proper tie-break procedure. The claimant's whistleblowing claim failed because, while some communications constituted protected disclosures, they played no part in the dismissal decision. The health and safety dismissal claim failed because the claimant was not 'designated' for health and safety activities beyond his ordinary duties.

Practical note

A claimant alleging whistleblowing dismissal cannot succeed merely by showing temporal coincidence between raising concerns and redundancy; they must prove protected disclosures actually caused or materially influenced the dismissal, which is difficult where the redundancy process is objectively fair and part of a genuine large-scale reorganisation.

Legal authorities cited

Iceland Frozen Foods v Jones [1983] ICR 17Post Office v Foley; HSBC Bank v Madden [2000] IRLR 827Castano v London General Transport Services Ltd [2020] IRLR 417Kilraine v London Borough of Wandsworth [2018] ICR 1850Sainsbury's Supermarkets Ltd v Hitt [2003] ICR 111Williams v Compair Maxam [1982] ICR 156Cavendish Munro Professional Risks Management Ltd v Geduld [2010] ICR 325Chesterton Global Ltd v Nurmohamed [2018] ICR 731

Statutes

ERA 1996 s.43BERA 1996 s.43CERA 1996 s.105(3)ERA 1996 s.105(6A)ERA 1996 s.94ERA 1996 s.98ERA 1996 s.100(1)(a)ERA 1996 s.103A

Case details

Case number
2206663/2020
Decision date
19 December 2025
Hearing type
full merits
Hearing days
6
Classification
contested

Respondent

Sector
retail
Represented
Yes
Rep type
barrister

Employment details

Role
Out of Hours Duty Manager
Salary band
£50,000–£60,000
Service
3 years

Claimant representation

Represented
No