Cases2304148/2023

Claimant v London Fire Brigade

18 September 2025Before Employment Judge TuejeLondon South

Outcome

Partly successful

Individual claims

Discrimination Arising from Disability (s.15)(disability)struck out

At a preliminary hearing on 23rd October 2024, EJ Wright found that the claimant had not submitted sufficient evidence to show he was disabled at the relevant time under s.6 Equality Act 2010. The claim for disability discrimination was therefore dismissed and struck out.

Unfair Dismissalsucceeded

The tribunal found the dismissal unfair because: (1) the investigation was unreasonable due to the supervisor's likely bias and unreliable evidence regarding CCTV; (2) the procedure was unfair — the claimant was not informed in time that CCTV would be destroyed, depriving him of the opportunity to preserve it; (3) dismissal was not a proportionate sanction given the claimant expressed remorse and there were no proper grounds for concluding he posed a risk to others.

Holiday Payfailed

Under clause 13 of the claimant's contract, only statutory holiday entitlement (7.5 days) was payable on termination; additional contractual days were forfeited. The claimant was paid the 7.5 days he was entitled to. There was no evidence of any agreement outside the contract to pay the additional 8.5 days, and no approval under the respondent's PN367 procedure.

Unlawful Deduction from Wagesfailed

The wages claim consisted entirely of the holiday pay claim. The tribunal found the claimant was only entitled to 7.5 days statutory holiday pay on termination, which had been paid. Therefore no unlawful deduction occurred.

Facts

The claimant, a hydrant technician employed by the London Fire Commissioner since August 2019, was summarily dismissed for gross misconduct following an altercation with a member of the public at a Tesco store on 10 October 2022. The complainant alleged the claimant shoved her to the ground during a dispute over queue-jumping. The respondent investigated, relying heavily on the store manager's account of CCTV footage (which was later destroyed) and witness statements. The claimant denied assaulting the complainant, stating he raised his arm defensively when she leaned into him. He was dismissed on 18 April 2023 and the dismissal was upheld on appeal.

Decision

The tribunal found the unfair dismissal claim succeeded. Although the respondent had reasonable grounds for belief at the time of dismissal, the investigation was tainted by the supervisor's likely bias (evidenced by a highly negative character reference inconsistent with the claimant's clean record), incomplete CCTV evidence, and procedural unfairness in failing to preserve CCTV or inform the claimant it would be destroyed. Dismissal was not a proportionate sanction. The holiday pay and wages claims failed because the claimant was only entitled to statutory holiday pay on termination, which had been paid.

Practical note

A dismissal may be unfair even if the decision-maker had reasonable grounds for belief at the time, where the investigation is subsequently shown to have been tainted by bias and procedural irregularities that deprived the employee of a fair opportunity to respond, particularly regarding key evidence like CCTV.

Legal authorities cited

London Ambulance Service NHS Trust v Small [2009] IRLR 563BHS v Burchell [1978] IRLR 379Sainsbury's Supermarkets Ltd v Hitt [2003] ICR 111Iceland Frozen Foods v Jones [1983] ICR 17Foley v Post Office [2000] ICR 1283

Statutes

Employment Rights Act 1996 s.98Employment Rights Act 1996 s.95Employment Rights Act 1996 s.27Employment Rights Act 1996 s.13Equality Act 2010 s.6Employment Rights Act 1996 s.94

Case details

Case number
2304148/2023
Decision date
18 September 2025
Hearing type
full merits
Hearing days
4
Classification
contested

Respondent

Sector
emergency services
Represented
Yes
Rep type
barrister

Employment details

Role
hydrant technician
Service
4 years

Claimant representation

Represented
No