Cases6005624/2024

Claimant v DWA Claims Limited

20 June 2025Before Employment Judge HaySouthamptonremote video

Outcome

Claimant fails

Individual claims

Constructive Dismissalfailed

Tribunal found the claimant resigned because the respondent would not pay what he thought he was worth, because of management changes, and because he was unhappy with the new commission structure. The tribunal found the respondent's conduct in relation to pay and commission was not unreasonable, but did find a wholesale failure to conduct a proper grievance procedure. However, the tribunal concluded the grievance failure played no part in the claimant's decision to resign, so the claim failed.

Breach of Contractfailed

Claimant sought release from a non-compete clause. The tribunal ruled it had no jurisdiction to retrospectively draft and apply employment contract terms to avoid consequences of terms the claimant had negotiated and agreed.

Unlawful Deduction from Wageswithdrawn

Claim for unpaid commission was resolved by the time of the hearing and was not pursued.

Facts

Claimant worked as a business development manager for a credit hire company from November 2013 to March 2024. In October 2022 he requested a pay increase. The respondent reviewed pay and commission structures, ultimately offering an increase from £30,000 to £45,000 basic salary plus a revised commission structure. Claimant was dissatisfied, seeking £55,000. He complained by email in November 2023 about feeling discriminated against regarding pay. The respondent treated this as a formal grievance but conducted no proper procedure and provided no outcome. Claimant resigned on 1 February 2024 during his one-month notice period.

Decision

The tribunal found the claimant resigned because he was unhappy with his pay and commission, not because of any breach of the implied term of trust and confidence. Although the respondent wholesale failed to conduct a proper grievance procedure - which would normally constitute a serious breach - the tribunal found this failure played no part in the claimant's decision to resign. The constructive dismissal claim therefore failed. The tribunal also dismissed a claim seeking release from a non-compete clause, ruling it had no jurisdiction to retrospectively amend contractual terms the claimant had negotiated.

Practical note

Even an egregious breach of employment rights (such as wholesale failure to conduct a grievance procedure) will not support a constructive dismissal claim if the tribunal finds that breach was not in fact a reason for the employee's resignation.

Legal authorities cited

Malik v Bank of Credit and Commerce International [1998] AC 20Sharfudeen v TJ Morris Limited (trading as Home Bargains) EAT 0272/16Frankel Topping Limited v King EAT 0106/15SC Gardner Limited v Berrisford [1978] IRLR 63 EATWA Goold (Pearmak) Limited v McConnell [1995] IRLR 516Blackburn v Aldi Stores Limited [2013] UKEAT/0185/12/JOJ

Statutes

ERA 1996 s.95ERA 1996 s.111ERA 1996 s.207B

Case details

Case number
6005624/2024
Decision date
20 June 2025
Hearing type
full merits
Hearing days
2
Classification
contested

Respondent

Sector
financial services
Represented
Yes
Rep type
in house

Employment details

Role
Business Development Manager
Salary band
£40,000–£50,000
Service
10 years

Claimant representation

Represented
Yes
Rep type
lay rep