Cases2225841/2024

Claimant v Unite the Union

Outcome

Other

Individual claims

Detrimentnot determined

This was a preliminary hearing on strike-out and deposit order applications. The tribunal refused to strike out the claims that the respondent, as both employer and independent trade union, subjected employees to detriment for taking part in trade union activities, finding the claimants had a reasonable prospect of success on some (but not all) of the alleged activities.

Harassment(sex)not determined

Preliminary hearing only. The tribunal found that the first two claimants had a reasonable prospect of establishing that an email alleging sexism and misogyny constituted harassment related to sex, noting the assessment would be fact-sensitive and depend on wider context and the claimants' perception.

Harassment(religion)not determined

Preliminary hearing only. The tribunal refused to strike out or order deposits on harassment claims related to belief in moderate left-wing socialism, finding the claimants had a reasonable prospect of establishing this as a protected philosophical belief and that the conduct complained of related to it.

Facts

Three employees of Unite the Union brought claims of detriment for trade union activities and harassment. The unusual feature was that they claimed their employer (Unite) had subjected them to detriments for taking part in activities of an independent trade union (also Unite). They alleged detriments relating to: lodging collective grievances via the Officers National Committee, implementing a motion for the ONC to join another union, and supporting an unsuccessful candidate in Unite's General Secretary election. Two claimants also claimed harassment related to sex and belief in moderate left-wing socialism, arising from an email alleging sexism and misogyny. Unite applied to strike out the claims or for deposit orders.

Decision

The tribunal refused to strike out any claims, finding the claimants had a reasonable prospect of success on most allegations. However, deposit orders of £500 each were made against specific arguments: that implementing a motion for the ONC to leave Unite was a trade union activity of Unite itself, and that supporting an unsuccessful General Secretary candidate was a Unite trade union activity. The tribunal found these particular arguments had little reasonable prospect of success but allowed the other claims to proceed to full hearing.

Practical note

An employer which is also a trade union can in principle be subject to claims under s.146 TULRCA 1992 by its own employee-members, but not all activities of union members are necessarily 'activities of the independent trade union' — the test is fact-sensitive and actions contrary to the union's interests are unlikely to qualify.

Legal authorities cited

Anyanwu v South Bank Student Union [2001] ICR 391Mechkarov v Citibank N.A [2016] ICR 1121Hasan v Tesco Stores Ltd EAT 0098/16H v Ishmail 2017 ICR 468Chant v Aquaboats Ltd [1978] ICR 643Grainger plc and ors v Nicholson 2010 ICR 360General Municipal and Boilermakers Union v Henderson 2015 IRLR 451Bakkali v Greater Manchester (South) t/a Stage Coach Manchester [2018] I.C.R. 1481Carozzi v University of Hertfordshire [2024] EAT 169Worcestershire Health and Care NHS Trust v Allen [2024] EAT 40Amber v West Yorkshire Fire and Rescue Service [2024] EAT 146

Statutes

Trade Union and Labour Relations (Consolidation) Act 1992 s.5Trade Union and Labour Relations (Consolidation) Act 1992 s.146Equality Act 2010 s.10Equality Act 2010 s.26Trade Union and Labour Relations (Consolidation) Act 1992 s.1

Case details

Case number
2225841/2024
Decision date
25 July 2025
Hearing type
preliminary
Hearing days
2
Classification
contested

Respondent

Sector
other
Represented
Yes
Rep type
barrister

Claimant representation

Represented
Yes
Rep type
barrister