Cases6019063/2025

Claimant v HCA International Limited

23 July 2025Before Employment Judge T.R. SmithLondon Centralin person

Outcome

Other

Individual claims

Automatic Unfair Dismissalnot determined

This was an interim relief application only. The tribunal refused the application, finding the claimant did not have a 'pretty good chance' of success in establishing that the reason or principal reason for dismissal was the protected disclosure. The tribunal noted a genuine redundancy process was documented, the restructure pre-dated the disclosure, and the claimant's factual assertions were disputed and not strongly supported by available documents.

Whistleblowingnot determined

The underlying whistleblowing claim (automatic unfair dismissal under s.103A ERA) remains to be determined at a full merits hearing. The interim relief application was refused because the tribunal was not satisfied the claimant had a pretty good chance of proving the dismissal was because of the protected disclosure.

Unfair Dismissalnot determined

Claim brought but not determined at this interim relief hearing.

Discrimination Arising from Disability (s.15)(disability)not determined

Claim brought but not the subject of this interim relief hearing and remains to be determined.

Detrimentnot determined

Whistleblowing detriment claims brought but not the subject of this interim relief hearing and remain to be determined.

Redundancy Paynot determined

Claim brought but not the subject of this interim relief hearing and remains to be determined.

Breach of Contractnot determined

Notice pay claim brought but not the subject of this interim relief hearing and remains to be determined.

Holiday Paynot determined

Claim brought but not the subject of this interim relief hearing and remains to be determined.

Unlawful Deduction from Wagesnot determined

Arrears of pay and other payments claimed but not the subject of this interim relief hearing and remain to be determined.

Victimisationnot determined

Possible victimisation claim or amendment application noted by the tribunal but not yet formally determined or subject of this hearing.

Facts

The claimant, a Senior Business Operations Manager employed since May 2022, alleged she made protected disclosures in March and October 2024 regarding NHS overcharging and patient prioritisation. She was placed at risk of redundancy in August 2024 as part of a restructure disbanding the non-clinical flex pool, and dismissed by reason of redundancy in May 2025 with 12 weeks' notice ending 6 August 2025. The claimant contended she had been given a substantive role outside the flex pool and was wrongly included in the redundancy pool, and that her dismissal was because of her whistleblowing.

Decision

The tribunal refused the claimant's application for interim relief, finding she did not have a 'pretty good chance' of establishing that the reason or principal reason for dismissal was her protected disclosure. The tribunal noted a documented redundancy process existed, the restructure pre-dated the alleged disclosure, and the respondent had arguable answers to each of the claimant's points. The tribunal found insufficient evidence on the available documents to infer the dismissal was connected to whistleblowing.

Practical note

Interim relief applications in whistleblowing dismissals require near-certain prospects of success on causation, and will fail where a genuine redundancy process is documented and pre-dates the disclosure, even if procedural fairness issues are raised.

Legal authorities cited

Cavendish Munro Professional Risks Management Ltd v Geduld [2010] ICR 325London City Airport Ltd v Chacko [2013] IRLR 610Goode v Marks & Spencer plc UKEAT/044/09Kilraine v London Borough of Wandsworth [2018] ICR 1850Kraus v Penna [2004] IRLR 260Abernethy v Mott, Hay and Anderson [1974] ICR 323Nicol v World Travel and Tourism Council [2024] ICR 893Western Union Payment Services UK Ltd v Anastasiou UKEAT/0135/13/LABoulding v Land Securities Trillium (Media Services) Ltd EAT/0023/06Chesterton Global Ltd v Nurmohamed [2018] ICR 731Taplin v C Shippam Ltd [1978] IRLR 450Ministry of Justice v Sarfraz [2011] IRLR 562

Statutes

ERA 1996 s.43AERA 1996 s.43BERA 1996 s.103AERA 1996 s.43C

Case details

Case number
6019063/2025
Decision date
23 July 2025
Hearing type
interim relief
Hearing days
1
Classification
contested

Respondent

Sector
healthcare
Represented
Yes
Rep type
barrister

Employment details

Role
Senior Business Operations Manager
Service
3 years

Claimant representation

Represented
Yes
Rep type
barrister