Cases3302637/2025

Claimant v ICTS UK and Ireland

7 August 2025Before Employment Judge S MooreNorwichremote video

Outcome

Claimant fails

Individual claims

Unfair Dismissalnot determined

Respondent asserts claimant does not have necessary length of service. Matter not determined at this interim relief hearing.

Automatic Unfair Dismissalfailed

Tribunal found no protected disclosure was made prior to dismissal on 9 May 2025. The Subject Access Request (16 May) and complaints to regulatory authorities were made after dismissal. The tribunal was not satisfied it is likely the reason for dismissal was a protected disclosure.

Whistleblowingfailed

Application for interim relief dismissed. No evidence of any protected disclosure made to employer before dismissal. Email of 9 May 2025 showed dismissal was because respondent believed claimant failed vetting process, not due to any disclosure.

Unlawful Deduction from Wagesnot determined

Claim for arrears of pay made in claim form. Respondent states all wages due have been paid. Matter not determined at this interim relief hearing.

Holiday Paynot determined

Claim for holiday pay made in claim form. Respondent asserts holiday pay has been paid. Matter not determined at this interim relief hearing.

Facts

Claimant was employed from 22 April to 9 May 2025, dismissed during probation on grounds he failed security vetting. He asserted the vetting was mishandled and his school confirmed it never received a vetting request. He subsequently made a Subject Access Request and complaints to the Civil Aviation Authority. The respondent discovered an administrative error had occurred in uploading reference dates but maintained the dismissal as they had onboarded too many employees and needed to reduce intake numbers.

Decision

The tribunal dismissed the application for interim relief because the claimant had not made any protected disclosure before his dismissal on 9 May 2025. The Subject Access Request and complaints to regulatory authorities were made after dismissal and therefore could not be the reason for it. There was evidence the dismissal was because the respondent believed he had failed vetting, not due to any disclosure.

Practical note

For an interim relief application in a whistleblowing dismissal claim to succeed, the alleged protected disclosure must have been made before the dismissal occurred; post-dismissal complaints cannot form the basis of a s.103A ERA claim.

Legal authorities cited

Kilraine v London Borough of Wandsworth [2018] ICR 1850Taplin v C Shippam Ltd [1978] ICR 1068Ministry of Justice v Sarfraz [2011] IRLR 562London City Airport Ltd v Chacko [2013] IRLR 610Parsons v Airbus UKEAT/0023/16/JOJCavendish Munro Professional Risks Management Ltd v Geduld [2010] ICR 325

Statutes

ERA 1996 s.103AERA 1996 s.43AERA 1996 s.43BERA 1996 s.43CERA 1996 s.128

Case details

Case number
3302637/2025
Decision date
7 August 2025
Hearing type
interim relief
Hearing days
1
Classification
contested

Respondent

Sector
transport
Represented
Yes
Rep type
lay rep

Claimant representation

Represented
No