Cases2413027/2023

Claimant v Y

8 July 2025Before Employment Judge Miller-VareyManchesterremote video

Outcome

Claimant succeeds£1,072

Individual claims

Unfair Dismissalsucceeded

The tribunal found no reasonable grounds for the employer's belief in misconduct; there was no reasonable investigation whatsoever and dismissal was well beyond the range of reasonable responses. The employer failed to provide any fair procedure, making a predetermined decision without hearing the claimant's account or conducting any meaningful investigation.

Wrongful Dismissalsucceeded

The claimant was summarily dismissed without notice pay. The tribunal found no gross misconduct had occurred, as there was insufficient persuasive evidence that the claimant engaged in consensual kissing with Z. The claimant was entitled to 5 weeks' notice which was not paid.

Unlawful Deduction from Wagessucceeded

The tribunal found the respondent made an unauthorised deduction of £1072.12 net wages for July 2023. The claimant's evidence was consistent and credible, supported by contemporaneous messages to the respondent and HMRC. The respondent failed to provide evidence of actual payment.

Holiday Paynot determined

Liability and quantum for holiday pay including 230.5 hours and payment in lieu for untaken leave on termination were expressly reserved to a further hearing. The tribunal made preliminary observations but did not determine the claim.

Facts

X worked as personal assistant and carer to Y's adult son Z who has autism. On 16 June 2023 both X and Y were separately contacted by Safeguarding about an allegation that X had kissed Z. X denied it. Y dismissed X summarily on 1 September 2023 without investigation or hearing, claiming gross misconduct. Y later claimed she had previous concerns about bruising and a November 2022 allegation but never raised these with X and they were not mentioned in her pleaded defence.

Decision

The tribunal found the dismissal unfair: there were no reasonable grounds for belief in misconduct, no investigation, no fair procedure, and dismissal was outside the range of reasonable responses. The tribunal rejected Polkey and contributory fault arguments. Wrongful dismissal and unlawful deduction of £1072.12 wages also succeeded. A 25% ACAS uplift was applied. Remedy to be assessed at further hearing.

Practical note

An employer cannot fairly dismiss on the basis of a third-party safeguarding allegation alone without conducting any investigation or giving the employee a proper hearing, even where the allegation concerns a vulnerable person in the employee's care and police are investigating.

Award breakdown

Arrears of pay£1,072

Adjustments

ACAS uplift+25%

Numerous unreasonable failures by respondent to comply with ACAS Code including failure to investigate, notify of case to answer, hold a disciplinary meeting, allow employee to set out case, and provide impartial appeal. Maximum 25% uplift applied.

Legal authorities cited

BHS v Burchell [1978] IRLR 379Taylor v OCS Group Limited [2006] EWCA Civ 702Scottish Special Housing Association v Cooke [1979] IRLR 264Leach v OFCOM [2012] IRLR 839L v K [2021] CSIH 35Sandwell & West Birmingham Hospitals NHS Trust v Westwood UKEAT/0032/09Software 2000 Limited v Andrews [2007] ICR 825Nelson v BBC (No.2) [1980] ICR 110Smith v Pimlico Plumbers No.2 [2022] EWCA Civ 70Damilare Ajao v Commerzbank AG [2024] EAT 11Sainsbury's Supermarkets Ltd v Hitt [2003] ICR 111Polkey v A E Dayton Services Ltd [1988] ICR 142Boys and Girls Welfare Society v McDonald [1996] IRLR 129Ham v Governing Body of Bearwood Humanities College UKEAT/0397/13/MC

Statutes

Trade Union & Labour Relations (Consolidation) Act 1992 s.207ASexual Offences Amendment Act 1992Working Time Regulations 1998Employment Rights Act 1996 s.13Employment Rights Act 1996 s.98

Case details

Case number
2413027/2023
Decision date
8 July 2025
Hearing type
full merits
Hearing days
1
Classification
contested

Respondent

Name
Y
Sector
healthcare
Represented
Yes
Rep type
lay rep

Employment details

Role
Personal assistant and carer
Service
6 years

Claimant representation

Represented
Yes
Rep type
barrister