Cases6023760/2025

Claimant v OCS Security Limited

24 September 2025Before Employment Judge BatyLondon Centralremote video

Outcome

Other

Individual claims

Automatic Unfair Dismissalnot determined

Interim relief application refused. Tribunal found claimant did not have a 'pretty good chance' of showing dismissal was principally because of alleged protected disclosure of 6 March 2025. Substantial contemporaneous evidence supported respondent's case that dismissal was for gross misconduct (being off route during assault incident, unauthorised activity, inconsistent accounts). Claimant provided no rational basis for causation beyond proximity in time. Additionally, tribunal doubted claimant had reasonable belief in health and safety breach or legal obligation breach, meaning alleged disclosure may not qualify as protected.

Facts

Claimant was a Mobile Security Supervisor dismissed on 22 June 2025 after three years' service. On 26/27 January 2025 he was assaulted during what respondent alleges was unauthorised activity off his designated patrol route on Robert Street. On 6 March 2025 claimant sent email alleging health and safety breaches which he relied on as protected disclosure. Respondent investigated and dismissed for gross misconduct, finding claimant was not working, was repeatedly off route, and gave inconsistent accounts. Claimant applied for interim relief and brought second consolidated claim in Watford tribunal including disability discrimination and other claims.

Decision

Interim relief application refused. Tribunal found claimant had no rational basis for showing protected disclosure was principal reason for dismissal, particularly given substantial contemporaneous evidence supporting gross misconduct rationale. Additionally, tribunal doubted claimant could show reasonable belief that disclosure tended to show health and safety breach or legal obligation breach. On summary assessment, tribunal considered claim unlikely to succeed at full hearing.

Practical note

Interim relief will be refused where the respondent presents substantial contemporaneous evidence of a non-whistleblowing reason for dismissal and the claimant relies solely on temporal proximity without establishing a rational causal link between disclosure and dismissal.

Legal authorities cited

Taplin v C Shippam Ltd [1978] ICR 1068Parsons v Airplus International Ltd UKEAT/0023/16Al Qasimi v Robinson EAT 0283/17Hancock v Ter-Berg [2020] ICR 570Dandpat v University of Bath UKEAT/0408/09Ministry of Justice v Sarfaz [2011] IRLR 562

Statutes

ERA 1996 s.43C-43HERA 1996 s.43BERA 1996 s.129ERA 1996 s.128ERA 1996 s.103AERA 1996 s.44ERA 1996 s.100ERA 1996 s.47B

Case details

Case number
6023760/2025
Decision date
24 September 2025
Hearing type
interim
Hearing days
1
Classification
contested

Respondent

Sector
professional services
Represented
Yes
Rep type
barrister

Employment details

Role
Mobile Security Supervisor
Service
3 years

Claimant representation

Represented
Yes
Rep type
lay rep