Cases3200735/2025

Claimant v Britvic Soft Drinks Limited

24 September 2025Before Employment Judge S PoveyEast Londonin person

Outcome

Claimant fails

Individual claims

Automatic Unfair Dismissalnot determined

This was an interim relief application under s.128-132 ERA 1996, not a final hearing. The tribunal found the claimant did not establish that it was 'likely' (a high threshold requiring 'something nearer to certainty than mere probability') that he would succeed in showing his dismissal was for making protected disclosures. The substantive claim remains to be determined at a full hearing.

Whistleblowingnot determined

The tribunal was not satisfied at this interim stage that the claimant's alleged disclosures met the legal definition of protected disclosures under Part IVA ERA 1996, with material shortcomings including whether they were disclosures of information rather than opinions, what wrongdoing was disclosed, and whether the public interest test was met. The substantive claim remains to be determined.

Facts

The claimant was employed as a Team Technician from February 2024 until dismissal on 15 August 2024. In February 2025, he was spoken to about alleged discrepancies in overtime records and went on sick leave. Following an investigation, he was dismissed for authorising and accepting payment for overtime he had not worked, leaving early during overtime periods, and failing to correct overpayments. The claimant alleged he made protected disclosures including in an email on 1 July 2025 about reporting matters to management and becoming a target, and multiple emails in June 2025 about unlawful deduction of wages. He applied for interim relief claiming automatic unfair dismissal for whistleblowing.

Decision

The tribunal dismissed the interim relief application. The judge found the claimant failed to establish the high threshold required for interim relief - that it was 'likely' (something nearer to certainty than mere probability) he would succeed at full hearing. Material shortcomings existed as to whether the alleged disclosures met the legal definition of protected disclosures, and the chronology suggested the disciplinary process began before the alleged disclosures were made. The substantive claims remain to be determined at a full hearing.

Practical note

Interim relief applications require a significantly higher threshold than the balance of probabilities - claimants must show a 'pretty good chance' approaching near certainty of success, and chronology showing disciplinary action commenced before alleged protected disclosures is fatal to causation.

Legal authorities cited

Taplin v C Shippam Ltd [1978] ICR 1068Al Qasimi v Robinson EAT 0283/17Ministry of Justice v Sarfraz [2011] IRLR 562London City Airport Ltd v Chacko UKEAT/0013/13/LADandpat v University of Bath EAT 0408/09

Statutes

ERA 1996 s.128-132Employment Tribunal Procedure Rules 2024 Rule 94ERA 1996 s.129(1)ERA 1996 Part IVAERA 1996 s.103A

Case details

Case number
3200735/2025
Decision date
24 September 2025
Hearing type
interim relief
Hearing days
1
Classification
contested

Respondent

Sector
manufacturing
Represented
Yes
Rep type
barrister

Employment details

Role
Team Technician
Service
6 months

Claimant representation

Represented
Yes
Rep type
lay rep