Cases6036897/2025

Claimant v Trelya

22 October 2025Before Employment Judge LiveseyBristolremote video

Outcome

Claimant fails

Individual claims

Whistleblowingnot determined

This was an interim relief application under s.128 ERA 1996. The tribunal found it was not likely that the claimant would succeed at full hearing in establishing that protected disclosures were the principal reason for dismissal. While some disclosures may have qualified, causation was the main issue - the respondent's case was that dismissal resulted from the claimant's refusal to accept probationary development points, not the disclosures themselves. The interim relief application was dismissed.

Discrimination Arising from Disability (s.15)(disability)not determined

The claimant brought disability discrimination claims alongside whistleblowing, but the interim relief hearing focused solely on the whistleblowing aspects under s.128. The disability discrimination claims were not addressed at this preliminary stage and remain to be determined at a future full hearing.

Facts

The claimant worked as a Community Health and Wellbeing Worker for a charity from March to September 2025. She raised concerns about safety protocols for outreach work in unknown households, arguing her team lacked risk information and safety equipment. Her probation was extended in September 2025 citing lack of confidence in outreach work. When she refused to sign the probationary extension letter, her employment was terminated on 30 September 2025. She claimed the dismissal was because of her protected disclosures about health and safety.

Decision

The tribunal dismissed the interim relief application. While some disclosures may have qualified as protected disclosures made in the public interest to appropriate recipients, the tribunal found it was not likely the claimant would succeed on causation. The evidence suggested dismissal resulted from her refusal to accept probationary development points, not her disclosures. The respondent had been receptive to health and safety concerns raised.

Practical note

Interim relief applications for whistleblowing dismissals require a 'pretty good chance' of success on all elements including causation, which remains the key battleground even where protected disclosures are likely established.

Legal authorities cited

Kilraine v London Borough of Wandsworth [2018] ICR 1850Western Union v Anastasiou UKEAT/0135/13/LATwist DX v Armes UKEAT/0030/20/JOJKorashi v Abertawe University Local Health Board [2012] IRLR 4Kraus v Penna [2004] IRLR 260Ibrahim v HCA UKEAT/0105/18Parsons v Airplus International Ltd UKEAT/0111/17Smith v Hayle Town Council [1978] ICR 996Tedeschi v Hosiden Besson Ltd EAT 959/95Ross v Eddie Stobart [2013] UKEAT/0068/13/RNBabula v Waltham Forest College [2007] ICR 1026Chesterton Global Ltd v Nurmohamed [2018] ICR 731Kuzel v Roche Products Ltd [2008] ICR 799Taplin v C Shippham Ltd [1978] ICR 1068Dandpat v University of Bath UKEAT/0408/09

Statutes

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

Case details

Case number
6036897/2025
Decision date
22 October 2025
Hearing type
interim
Hearing days
1
Classification
contested

Respondent

Name
Trelya
Sector
charity
Represented
Yes
Rep type
barrister

Employment details

Role
Community Health and Wellbeing Worker
Service
6 months

Claimant representation

Represented
No