Cases1406352/2023

Claimant v Advisory Insurance Brokers Limited

22 June 2025Before Employment Judge Elizabeth GibsonExeterremote video

Outcome

Claimant fails

Individual claims

Constructive Dismissalfailed

The tribunal found the claimant resigned of her own volition after securing a new job, not because of any fundamental breach of contract by the respondent. The respondent's conduct in failing to replace the PA and the oversight in not responding to questions about restructuring did not meet the high threshold of the Malik test to constitute a breach of the implied term of trust and confidence. The conduct was neither calculated nor likely to destroy or seriously damage trust and confidence.

Facts

The claimant was employed as an Executive Assistant from June 2018 to August 2023. From November 2022, she covered a part-time PA role after that colleague left, with no replacement recruited for nine months. In June 2023, a restructure created a new Team Leader role which the claimant was interested in, but she alleged the recruitment process was handled poorly with HR failing to answer her questions. The claimant secured a new job on 28 July 2023 and resigned on 1 August 2023, citing both the PA cover issue and the restructuring process.

Decision

The tribunal dismissed the constructive dismissal claim, finding the claimant resigned voluntarily after securing new employment, not because of any fundamental breach of contract. The respondent's conduct in failing to replace the PA and the HR oversight in not responding to questions did not meet the Malik test threshold for breaching the implied term of trust and confidence. The conduct was neither calculated nor objectively likely to destroy or seriously damage the employment relationship.

Practical note

An employee's genuine frustration with employer inefficiency and poor HR communication does not automatically constitute a breach of the implied term of trust and confidence; the Malik test sets a high threshold requiring conduct that is calculated or objectively likely to destroy or seriously damage the employment relationship, and securing alternative employment before resigning may indicate the resignation was voluntary rather than constructive dismissal.

Legal authorities cited

Western Excavating v Sharp [1978] ICR 221Malik v Bank of Credit and Commerce International [1998] AC 20Woods v WM Car Services (Peterborough) Limited [1981] IRLR 347 CAFrenkel Topping Limited v King EAT 0106/15Morrow v Safeway Stores Plc [2002] IRLR 9 EATKaur v Leeds Teaching Hospitals NHS Trust [2018] IRLR 883BG plc v O'Brien [2001] IRLR 496

Statutes

ERA 1996 s.95(1)(c)ERA 1996 s.98(4)

Case details

Case number
1406352/2023
Decision date
22 June 2025
Hearing type
full merits
Hearing days
2
Classification
contested

Respondent

Sector
financial services
Represented
Yes
Rep type
barrister

Employment details

Role
Executive Assistant
Service
5 years

Claimant representation

Represented
No