Cases3308895/2023

Claimant v London Underground Limited

30 October 2025Before Employment Judge BaranReadingremote video

Outcome

Claimant fails

Individual claims

Unfair Dismissalsucceeded

The tribunal previously found at liability that the dismissal was unfair because the respondent based the dismissal of the claimant's appeal on lack of qualifications without properly appraising the adequacy of his newly obtained qualifications and without giving him the opportunity to respond. No reasonable employer could treat his paper qualifications as insufficient when they were on the face of it sufficient at the time of the appeal.

Facts

This was a remedy hearing following a finding of unfair dismissal. The claimant had been dismissed as a Plant Fitter for lack of qualifications. Although he obtained relevant qualifications before his appeal was concluded, these were not properly considered. At the remedy hearing, the claimant sought reinstatement or re-engagement. The respondent argued he lacked the necessary post-qualification experience now required for safety critical roles and that he would have been fairly dismissed in any event.

Decision

The tribunal refused reinstatement and re-engagement on grounds of impracticability, finding the claimant did not meet genuine safety critical requirements including 2 years verifiable post-qualification experience. The tribunal applied a 100% Polkey reduction to the compensatory award, finding that even with a fair appeal procedure the claimant would likely have been fairly dismissed within 2-3 months once the respondent had properly considered the adequacy of his experience for the safety critical role.

Practical note

Even where an unfair dismissal is established, reinstatement or re-engagement will not be ordered where the employee cannot demonstrate they meet genuinely designated essential requirements for safety critical roles, and a 100% Polkey reduction may apply where the employer would inevitably have dismissed fairly shortly thereafter.

Adjustments

Polkey reduction100%

The tribunal found that even if the appeal had been conducted fairly, the claimant would likely have been fairly dismissed within 2-3 months on grounds of lack of demonstrable post-qualification experience necessary for the safety critical Plant Fitter role. The respondent would have introduced a requirement for 2 years verifiable post-qualification experience which the claimant could not demonstrate.

Legal authorities cited

Polkey v A E Dayton Services Ltd [1988] ICR 142Lincolnshire County Council v Lupton [2016] IRLR 576Davies v DL Insurance Services Ltd [2020] IRLR 490Kelly v PGA European Tour [2021] IRLR 575Britool Ltd v Roberts [1993] IRLR 481King v Eaton Ltd (No2) [1998] IRLR 686O'Donoghue v Redcar and Cleveland Borough Council [2001] IRLR 615Software 2000 Ltd v Andrews [2007] IRLR 568Hill v Governing Body of Great Tey Primary School [2013] ICR 691Coleman and Stephenson v Magnet Joinery Ltd [1974] IRLR 343King v Royal Bank of Canada [2012] IRLR 280

Statutes

ERA 1996 s.114ERA 1996 s.116ERA 1996 s.123ERA 1996 s.115

Case details

Case number
3308895/2023
Decision date
30 October 2025
Hearing type
remedy
Hearing days
1
Classification
contested

Respondent

Sector
transport
Represented
Yes
Rep type
barrister

Employment details

Role
Plant Fitter

Claimant representation

Represented
Yes
Rep type
lay rep