Cases2501858/2024

Claimant v Seaton Hospitality Limited

5 June 2025Before Employment Judge L RobertsonNewcastleremote video

Outcome

Partly successful£5,561

Individual claims

Unfair Dismissalsucceeded

The tribunal found that the respondent did not have reasonable grounds for its belief that the claimant was guilty of the allegations, and had not carried out a reasonable investigation by the time the decision to dismiss was formed. The claimant was not given a proper opportunity to respond to the evidence before dismissal was confirmed. The procedure was outside the band of reasonable responses and the dismissal was therefore unfair under s.98(4) ERA 1996.

Breach of Contractwithdrawn

Withdrawn by claimant at the hearing.

Facts

The claimant was Head Chef at the Roker Hotel. On 10 March 2024, undercooked turkey was served to guests at a Mothers' Day carvery event. The turkey had been cooked by a relatively new chef, Anthony, working in a separate ballroom kitchen. The claimant had not informed Anthony about equipment issues with the oven, had not supervised him adequately, and had not ensured proper temperature checking before service. Following an investigation and disciplinary process conducted by an external HR consultant, the claimant was summarily dismissed for gross misconduct on 3 April 2024.

Decision

The tribunal found the dismissal unfair because the respondent did not carry out a reasonable investigation before reaching the decision to dismiss, and did not have reasonable grounds for the belief that all allegations were made out. The decision-maker had formed her view before the reconvened disciplinary hearing and did not give the claimant a proper opportunity to respond to the investigation findings. However, the tribunal found the claimant's conduct was culpable and reduced both awards by 60%.

Practical note

A disciplinary decision-maker must not reach a final decision before giving the employee a proper opportunity to review and respond to all investigation findings, even where serious misconduct appears evident.

Award breakdown

Basic award£5,401
Compensatory award£160
Loss of statutory rights£160

Award equivalent: 8.0 weeks' gross pay

Adjustments

Contributory fault60%

The tribunal found the claimant neglected his duties by failing to properly brief and supervise a relatively new chef, such that undercooked turkey was served to guests. The claimant's conduct was culpable and blameworthy, contributing significantly to his dismissal. The basic award was reduced by 60% under s.122(2) ERA and the compensatory award by 60% under s.123(6) ERA.

Legal authorities cited

Sainsbury's Supermarkets Ltd v Hitt [2003] ICR 111Abernethy v Mott, Hay and Anderson [1974] ICR 323Croydon Health Services NHS Trust v Beatt [2017] ICR 1240Nelson v BBC (No.2) 1980 ICR 110Langston v Department for Business, Enterprise and Regulatory Reform EAT 0534/09Steen v ASP Packaging [2014] ICR 56Tayeh v Barchester Healthcare Ltd [2013] IRLR 387BHS v Burchell [1978] IRLR 379

Statutes

ERA 1996 s.98TUPE 2006ERA 1996 s.122(2)ERA 1996 s.123(6)

Case details

Case number
2501858/2024
Decision date
5 June 2025
Hearing type
full merits
Hearing days
2
Classification
contested

Respondent

Sector
hospitality
Represented
Yes
Rep type
lay rep

Employment details

Role
Head Chef
Salary band
£30,000–£40,000
Service
19 years

Claimant representation

Represented
Yes
Rep type
barrister