Cases1308533/2023

Claimant v Blanc Aero Industries UK Limited

10 December 2025Before Employment Judge Isabel ManleyBirmingham

Outcome

Partly successful£2,765

Individual claims

Unfair Dismissalsucceeded

The tribunal found that the respondent failed to carry out a reasonable investigation, did not follow its own disciplinary procedures (including failing to refer the matter to the claimant's manager as required), and predetermined the decision to dismiss before the resumed disciplinary hearing. The dismissal was outside the band of reasonable responses despite the serious nature of the misconduct, because the procedure was fundamentally flawed and failed to properly engage with the claimant's defence of workplace banter culture.

Facts

The claimant, a production operative with 15 years' service, was dismissed for gross misconduct after making offensive comments including calling a colleague a 'suicide bomber', telling another to 'fuck off back to Poland', making sexual comments to a female colleague, and other inappropriate remarks. The claimant's defence was that there was a widespread culture of workplace banter where people 'gave as good as they got', and that the complaint was raised maliciously by a departing colleague who was upset about a conversation concerning his eating disorder. The claimant had attended bullying and harassment training in May 2023 and argued the incidents occurred before this training.

Decision

The tribunal found the dismissal procedurally unfair due to multiple serious flaws: failure to investigate timing of incidents relative to training, failure to follow the employer's own procedures, predetermination of the outcome before the resumed hearing, and failure to properly investigate the claimant's defence of banter culture. However, the tribunal found a 100% Polkey reduction as the claimant would inevitably have been dismissed anyway given the egregious nature of the harassment, and an 80% contributory fault reduction to the basic award for blameworthy conduct. The claimant was awarded £2,764.90 (20% of basic award only).

Practical note

Even where a workplace banter culture exists and dismissal is procedurally unfair, tribunals may still apply 100% Polkey reductions where the misconduct amounts to serious unlawful harassment under the Equality Act 2010, effectively leaving the claimant with only a declaration of unfair dismissal and a heavily reduced basic award.

Award breakdown

Basic award£2,765

Adjustments

Polkey reduction100%

Tribunal found claimant would have been dismissed in any event had a fair procedure been followed, given the egregious nature of the comments (suicide bomber, racial and sexual harassment) which amounted to unlawful harassment under the Equality Act 2010. Dismissal would have occurred by the same date.

Contributory fault80%

Claimant's conduct was blameworthy despite workplace banter culture. He had been warned 9 months earlier that not everyone likes such banter and that the language was unacceptable. He nonetheless made extremely serious comments including racial, sexual and religious harassment.

Legal authorities cited

Polkey v A E Dayton Services Ltd [1988] ICR 142BHS v Burchell [1978] IRLR 379Iceland Frozen Foods v Jones [1983] ICR 17Salford Royal NHS Trust v Roldan [2010] EWCA Civ 522London Ambulance Service NHS Trust v Small [2009] EWCA Civ 220Orr v Milton Keynes Council [2011] ICR 704Royal Mail Ltd v Jhuti [2019] UKSC 55West Midlands Co-Op Ltd v Tipton [1986] ICR 192Software 2000 Ltd v Andrews [2007] ICR 825Steen v ASP Packaging Ltd [2014] ICR 56Granchester Construction (Eastern) Ltd v Attrill EAT 0327/12Sainsbury's Supermarkets Ltd v Hitt [2003] ICR 111W Devis and Sons Ltd v Atkins [1977] ICR 662Foley v Post Office and Midland Bank plc v Madden [2000] IRLR 82

Statutes

Employment Rights Act 1996 s.123(6)Equality Act 2010 s.109(4)Employment Rights Act 1996 s.122(2)Employment Rights Act 1996 s.98

Case details

Case number
1308533/2023
Decision date
10 December 2025
Hearing type
full merits
Hearing days
3
Classification
contested

Respondent

Sector
manufacturing
Represented
Yes
Rep type
in house

Employment details

Role
Production operative
Service
16 years

Claimant representation

Represented
No