Cases8001700/2024

Claimant v McPherson Ltd

29 May 2025Before Employment Judge E MannionScotlandin person

Outcome

Claimant fails

Individual claims

Constructive Dismissalfailed

The tribunal found the respondent's actions did not amount to a fundamental breach of the implied term of trust and confidence. The respondent had reasonable and proper cause for investigating the altercation informally, removing the claimant from the Blackgrange site following Diageo's request, and redeploying him to a road driving role. The email from Diageo's Mr Cai did not evidence that the respondent lied. The conduct was not calculated or likely to seriously damage the employment relationship on an objective assessment.

Breach of Contractfailed

The claimant resigned with immediate effect and did not work his notice period. As the resignation did not fall within a dismissal under Section 95(1) of the ERA, the respondent had no obligation to pay notice pay when the employee resigned with immediate effect.

Facts

The claimant worked for 20 years as a shunter at Diageo's Blackgrange site. Following a verbal altercation with a colleague on 5 April 2024, Diageo requested the claimant be removed from site. The respondent investigated informally, issued a letter of concern, and offered the claimant retraining as a road driver with support. The claimant went on sick leave due to work-related stress on 13 May 2024 and resigned on 8 June 2024, believing the respondent had lied about who decided to remove him from Blackgrange.

Decision

The tribunal dismissed both claims. The respondent's actions did not breach the implied term of trust and confidence. The respondent had reasonable cause to investigate the altercation, accept Diageo's decision to remove the claimant from site, and redeploy him to a road driving role. The claimant's belief that the respondent lied was not objectively supported by the evidence. As the resignation was not a constructive dismissal, no notice pay was due.

Practical note

An employee's subjective belief that an employer has acted improperly is insufficient for constructive dismissal; the tribunal applies an objective test to whether conduct was calculated or likely to seriously damage trust and confidence, and redeployment following a client's request does not ordinarily constitute a fundamental breach.

Legal authorities cited

Bournemouth University Higher Education Corporation v Buckland [2010] ICR 908Lewis v Motorworld Garages Ltd [1968] ICR 157Omilaju v Waltham Forest London Borough Council [2005] ICR 481Western Excavating v Sharp [1978] ICR 221Kaur v Leeds Teaching Hospitals NHS Trust [2019] ICR 1Lochuack v London Borough of Sutton EAT 0197/14Malik v Bank of Credit and Commerce International [1998] AC 20

Statutes

ERA 1996 s.95(1)(c)

Case details

Case number
8001700/2024
Decision date
29 May 2025
Hearing type
full merits
Hearing days
3
Classification
contested

Respondent

Sector
transport
Represented
Yes
Rep type
solicitor

Employment details

Role
HGV Driver/Shunter
Service
20 years

Claimant representation

Represented
Yes
Rep type
lay rep