Cases2400080/2023

Claimant v Mersey Care NHS Foundation Trust

2 July 2025Before Employment Judge AinscoughLiverpoolin person

Outcome

Partly successful£23,007

Individual claims

Constructive Dismissalsucceeded

The tribunal found that the respondent breached the implied term of trust and confidence by denying the claimant a right of appeal following a grievance investigation, taking a perverse view of her grievance as 'respect and civility' rather than 'resolution', and failing to provide the investigation report. The claimant resigned in response to this repudiatory breach which destroyed trust and confidence in the employment relationship.

Discrimination Arising from Disability (s.15)(disability)failed

Although the respondent treated the claimant unfavourably by downgrading her role and removing prescribing rights, and her sickness absence arose from her disability (depression), the tribunal found the unfavourable treatment was not because of her sickness absence but because of an audit of clinic practices and documents. The manager would have formed the same view even if the claimant had been in work.

Harassment(disability)failed

The tribunal found that while the advertisement of the claimant's role during her disability-related sick leave was unwanted conduct related to her disability, it did not have the purpose or effect of violating her dignity or creating a hostile environment. The claimant was reassured it was temporary cover and there was budget for her return. Other acts of harassment (restrictions on attending clinic, downgrading role) were not related to her disability but to other operational reasons.

Facts

The claimant was a band 7 advanced practitioner nurse specialising in mental health and clozapine treatment who worked for the respondent NHS Trust from 1995 to 2022. She suffered from depression and anxiety from 2017 and had extended periods of sick leave. Her line manager Nicola Lamont restricted her access to the clinic during sick leave, questioned her advanced practitioner status, and proposed she return as a clinic nurse. After a 16-month grievance process, the claimant was denied sight of the investigation report and told she had no right of appeal because it was categorised as 'respect and civility' not 'resolution'. She resigned on 7 July 2022 citing loss of trust and confidence.

Decision

The tribunal found the claimant was constructively unfairly dismissed. The respondent breached the implied term of trust and confidence by perversely categorising her grievance to deny her a right of appeal and access to the investigation report after 16 months. However, her discrimination arising from disability claim failed because the downgrading of her role was due to an audit, not her absence. Her harassment claim failed because most acts were not related to her disability, and the advertisement of her role, though related to disability, was reasonably explained as temporary cover. Compensation was limited to basic award and notice pay only because the tribunal found she would have been dismissed for long-term absence within two months even with a fair appeal process.

Practical note

Employers must follow their own grievance procedures transparently and fairly; misclassifying a grievance about terms and conditions as 'respect and civility' to deny an appeal can amount to a repudiatory breach, but compensation may be minimal if the employee would have been fairly dismissed shortly after for capability reasons.

Award breakdown

Basic award£14,275
Compensatory award£8,732

Award equivalent: 25.1 weeks' gross pay

Adjustments

Polkey reduction100%

The tribunal found that even if the claimant had been allowed to appeal her grievance, she would not have been fit to return to work and would have been dismissed at a stage 4 absence management meeting by 19 September 2022. Compensation was therefore limited to notice pay only, reflecting that dismissal would have occurred within approximately 2 months.

Legal authorities cited

Western Excavating v Sharp [1978] ICR 221Bournemouth University Higher Education Corporation v Buckland [2010] ICR 908Frenkel Topping Limited v King UKEAT/0106/15/LAGoold WA (Pearmak) Ltd v McConnell [1995] IRLR 516Blackburn v Aldi Stores Limited [2013] IRLR 846O'Donoghue v Redcar and Cleveland Borough Council (2001) IRLR 615Software 2000 Ltd v Andrews [2007] IRLR 568Williams v Amey Services Ltd EAT 0287/14Malik v Bank of Credit and Commerce International [1998] AC 20Polkey v A E Dayton Services Ltd [1988] ICR 142Hewage v Grampian Health Board [2012] UKSC 37Igen v Wong [2005] ICR 931Madarassy v Nomura International Plc [2007] ICR 867Hendricks v Metropolitan Police Commissioner [2003] ICR 530Leeds Dental Team Ltd v Rose [2014] IRLR 8

Statutes

Employment Rights Act 1996 s.119Employment Rights Act 1996 s.95(1)(c)Employment Rights Act 1996 s.123Equality Act 2010 s.15Equality Act 2010 s.26Equality Act 2010 s.39Equality Act 2010 s.136

Case details

Case number
2400080/2023
Decision date
2 July 2025
Hearing type
full merits
Hearing days
7
Classification
contested

Respondent

Sector
healthcare
Represented
Yes
Rep type
barrister

Employment details

Role
Registered advanced practitioner nurse
Salary band
£40,000–£50,000
Service
28 years

Claimant representation

Represented
No