Cases6004071/2025

Claimant v Care UK Services Limited

13 August 2025Before Employment Judge AndrewsLondon South

Outcome

Other

Individual claims

Constructive Dismissalnot determined

Interim relief application only. Tribunal found claimant did not have a pretty good chance of success on whistleblowing claim, but did not determine the underlying constructive dismissal claim which remains live.

Whistleblowingfailed

Tribunal found claimant did not have a pretty good chance of success at final hearing. First grievance (October 2021) did not clearly indicate protected disclosure - written as personal complaint. Second grievance (October 2024) slightly stronger but still insufficient, and causal link problematic as treatment predated the disclosure.

Direct Discriminationnot determined

Claim mentioned in judgment as one of multiple types of discrimination claimed, but not determined at this interim relief hearing.

Victimisationnot determined

Claim mentioned in judgment but not determined at this interim relief hearing.

Unlawful Deduction from Wagesnot determined

Claim for unpaid monies mentioned in judgment but not determined at this interim relief hearing.

Facts

Claimant resigned on 3 February 2025 and claimed constructive dismissal and automatic unfair dismissal due to whistleblowing. He relied on two grievances as protected disclosures: one from October 2021 regarding access to HARBOUR system and one from October 2024 regarding alleged breaches of Health and Social Care regulations. He was off sick from early December 2024 until resignation. He applied for interim relief within his claim form submitted 6 February 2025.

Decision

The tribunal refused the interim relief application. It found the claimant did not have a 'pretty good chance of success' at a final hearing of proving protected disclosures, as both grievances were predominantly personal complaints without clear indication of public interest disclosures. Even if disclosures were made, the causal link was weak - the 2021 grievance was too remote in time, and the 2024 grievance post-dated the treatment complained of.

Practical note

Interim relief applications under s.128 ERA require significantly higher prospects than mere balance of probabilities, and grievances must clearly indicate protected disclosures on their face rather than requiring construction or inference.

Legal authorities cited

Taplin v Shippam Ltd [1978] ICR 1068 EATMinistry of Justice v Sarfaz [2011] IRLR 562Dandpat v The University of Bath & ors UKEAT/0408/09

Statutes

ERA 1996 s.103AERA 1996 s.128(1)Health and Social Care Act 2008ERA 1996 s.129(1)

Case details

Case number
6004071/2025
Decision date
13 August 2025
Hearing type
preliminary
Hearing days
1
Classification
contested

Respondent

Sector
healthcare
Represented
Yes
Rep type
barrister

Claimant representation

Represented
Yes
Rep type
lay rep