Cases2501070/2023

Claimant v Tolent Construction Limited "In Administration"

29 July 2025Before Employment Judge ArullendranNorth Easton papers

Outcome

Claimant succeeds

Individual claims

Failure to Inform & Consultsucceeded

The respondent dismissed 20 or more employees as redundant at multiple sites without proper warning or consultation with a recognised trade union or the claimants, and no employee representatives had been elected or appointed. This constituted a clear breach of section 188 of the Trade Union and Labour Relations (Consolidation) Act 1992.

Facts

Tolent Construction Limited entered administration on 13 February 2023 and dismissed 45 employees as redundant across three sites in the North East and Yorkshire without consultation. The respondent failed to consult with a recognised trade union or the claimants themselves, and no employee representatives were elected or appointed as required by statute. The administrator agreed to lift the moratorium to allow protective award claims to proceed. The respondent did not defend the claims.

Decision

The tribunal found the respondent in breach of its duty under section 188 of the Trade Union and Labour Relations (Consolidation) Act 1992 and awarded the maximum protective award of 90 days remuneration to all 45 claimants. The judgment was entered under Rule 21 without a hearing as the respondent indicated it would not defend the claims.

Practical note

Even when a company enters administration, failure to comply with collective consultation requirements under TULR(C)A 1992 will result in the maximum 90-day protective award for affected employees.

Legal authorities cited

Statutes

Trade Union and Labour Relations (Consolidation) Act 1992 s.189Trade Union and Labour Relations (Consolidation) Act 1992 s.188Employment Protection (Recoupment of Jobseeker's Allowance and Income Support) Regulations 1996Trade Union and Labour Relations (Consolidation) Act 1992 s.189(3)Trade Union and Labour Relations (Consolidation) Act 1992 s.188A

Case details

Case number
2501070/2023
Decision date
29 July 2025
Hearing type
rule 21
Hearing days
Classification
default

Respondent

Sector
construction
Represented
No

Claimant representation

Represented
No