Cases1303020/2024

Claimant v Solair Limited

26 September 2025Before Employment Judge Edmondson papers

Outcome

Claimant succeeds

Individual claims

Failure to Inform & Consultsucceeded

The respondent failed to comply with statutory obligations to inform and consult under section 188 Trade Union and Labour Relations (Consolidation) Act 1992 regarding collective redundancies. The tribunal awarded a protective award for 90 days from the date of dismissal for this failure to consult.

Facts

The claimant was dismissed on 25 September 2023 as part of collective redundancies. She did not present her protective award claim until 26 February 2024, approximately 7.5 weeks outside the normal time limit. Her partner became seriously ill shortly after her dismissal, requiring constant care, and he remained hospitalised and bedbound until his death in September 2024. The claimant only learned of her right to claim a protective award in February 2024 from a colleague, at which point she promptly commenced ACAS early conciliation.

Decision

On reconsideration, the tribunal found it was not reasonably practicable for the claimant to present her claim on time due to her partner's serious illness requiring her constant care as his carer. The tribunal extended time to 26 February 2024, finding she acted within a reasonable further period once she learned of her rights. The claim for failure to inform and consult succeeded, with a protective award of 90 days granted.

Practical note

Serious personal circumstances, particularly caring responsibilities for a terminally ill partner, can justify extending time limits for protective award claims where the claimant acts promptly once aware of their rights.

Legal authorities cited

Porter v Bandridge Ltd [1978] ICR 943Cullinane v Balfour Beatty Engineering Services Ltd and anor EAT 0537/10Palmer and anor v Southend-on-Sea Borough Council [1984] ICR 372Dedman v British Building and Engineering Applicances Ltd [1974] ICR 53

Statutes

Trade Union and Labour Relations (Consolidation) Act 1992 s.189(5)Trade Union and Labour Relations (Consolidation) Act 1992 s.188

Case details

Case number
1303020/2024
Decision date
26 September 2025
Hearing type
reconsideration
Hearing days
Classification
procedural

Respondent

Sector
Represented
No

Claimant representation

Represented
No