Cases4100026/2025

Claimant v OH Assist Limited t/a Optima Health

15 July 2025Before Employment Judge D HoeyScotlandin person

Outcome

Partly successful£167

Individual claims

Victimisationwithdrawn

Withdrawn by claimant at the hearing after hearing the evidence and accepting that the protected acts were not a reason for his treatment.

Unfair Dismissalfailed

The tribunal found the dismissal was for a genuine redundancy situation arising from a diminution in the need for the claimant's unique senior data insights work. The decision to place the claimant in a pool of one was within the range of reasonable responses given his unique and more senior role compared to the reporting team. The consultation was meaningful, the claimant was given the opportunity to raise issues (including pooling) and the respondent genuinely considered alternatives. The appeal process was fair. The dismissal fell within the band of reasonable responses open to a reasonable employer.

Breach of Contractsucceeded

The parties agreed by consent that the respondent had erroneously deducted one day's gross pay from sums due to the claimant.

Facts

The claimant was employed as a Senior Data Insights Analyst from November 2019. His unique specialist role involved interpreting data and statistical analysis. Due to automation and diminishing client requirements, the work he was employed to do had significantly reduced. He had been given more junior reporting tasks to fill his time. In 2024, the respondent needed cost savings. Mr Harrison identified the claimant's unique role as at risk of redundancy and placed him in a pool of one. The claimant was consulted, raised concerns about pooling and the percentage of work disappearing, but ultimately accepted the rationale. He was dismissed for redundancy and his appeal heard by Mr Paxton was unsuccessful.

Decision

The tribunal found the dismissal was for a genuine redundancy arising from diminution of work. The decision to place the claimant in a pool of one was within the range of reasonable responses given his unique senior role, distinct from the junior reporting team. Consultation was meaningful and the claimant accepted the pooling rationale when explained during the process. The appeal was fairly conducted. The unfair dismissal claim failed. The victimisation claim was withdrawn. A small breach of contract claim for wrongly deducted pay succeeded by consent.

Practical note

A pool of one can be fair in redundancy where the employee's role is genuinely unique and substantially more senior than others doing superficially similar work, even if consultation on pooling does not occur before the process begins, provided the rationale is explained and accepted during consultation.

Award breakdown

Unpaid wages£167

Legal authorities cited

Williams v Compair Maxam [1982] ICR 156Lloyd v Taylor Woodrow Construction [1999] IRLR 782West Midland v Tipton [1986] ICR 192Iceland Frozen Foods v Jones [1983] ICR 17Polkey v A E Dayton Services Ltd [1988] ICR 142Taylor v OCS [2006] IRLR 613Mogane v Bradford Teaching Hospital [2022] EAT 139Valimulla v Al-Khair Foundation [2023] EAT 131Safeway Stores Plc v Burrell [1997] ICR 523Murray v Foyle Meats Ltd [2000] 1 AC 51

Statutes

ERA 1996 s.98ERA 1996 s.139

Case details

Case number
4100026/2025
Decision date
15 July 2025
Hearing type
full merits
Hearing days
3
Classification
contested

Respondent

Sector
healthcare
Represented
Yes
Rep type
barrister

Employment details

Role
Senior Data Insights Analyst
Service
5 years

Claimant representation

Represented
Yes
Rep type
lay rep