Cases1600187/2025

Claimant v Genu Prima Limited

22 September 2025Before Employment Judge A Lloyd-LawrieWalesin person

Outcome

Claimant fails

Individual claims

Automatic Unfair Dismissalfailed

The tribunal found that the claimant did not make a qualifying disclosure as required under section 103A Employment Rights Act 1996. Without a qualifying protected disclosure, the automatic unfair dismissal claim cannot succeed.

Whistleblowingfailed

The tribunal determined that the claimant did not make a qualifying disclosure. As a result, his claim for detriment on the grounds of protected disclosure under section 47B Employment Rights Act 1996 failed.

Facts

Mr Watters brought claims against Genu Prima Limited for automatic unfair dismissal and detriment arising from alleged protected disclosures. He represented himself at a one-day hearing in Cardiff. The central issue was whether the claimant had made a qualifying disclosure under whistleblowing legislation.

Decision

The tribunal found that the claimant had not made a qualifying disclosure. Consequently, both his automatic unfair dismissal claim under section 103A and his detriment claim under section 47B of the Employment Rights Act 1996 failed and were dismissed.

Practical note

Whistleblowing claims require the claimant to establish that they made a qualifying disclosure as a threshold matter; without this, both automatic unfair dismissal and detriment claims will fail at the outset.

Legal authorities cited

Statutes

ERA 1996 s.103AERA 1996 s.47B

Case details

Case number
1600187/2025
Decision date
22 September 2025
Hearing type
full merits
Hearing days
1
Classification
contested

Respondent

Sector
other
Represented
Yes
Rep type
lay rep

Claimant representation

Represented
No