Cases2410287/2023

Claimant v Bolton Cares (A) Limited

28 May 2025Before Employment Judge Victoria ButlerManchesterremote video

Outcome

Claimant fails

Individual claims

Constructive Dismissalpartly succeeded

The tribunal struck out specific allegations (6(c), 6(d), 6(m)) that formed part of the constructive dismissal claim due to failure to particularise and unreasonable conduct. However, other allegations forming part of the constructive dismissal claim remain to be heard at the final hearing in September 2025.

Working Time Regulationsstruck out

The entire Working Time Regulations claim (allegation 28) concerning alleged breach of Regulation 12(1) WTR for failure to provide rest breaks between January 2020 and May 2023 was struck out. The claimant failed to provide necessary particulars identifying specific dates, who refused breaks, and shift lengths despite repeated requests and tribunal directions over 14 months.

Breach of Contractpartly succeeded

The allegations concerning excessive working hours in breach of contract (6(c) and 6(d)) were struck out for failure to provide specific dates, who required excessive hours, and the extent of excess hours worked. These allegations spanned January 2020 to May 2023 but the claimant could not particularise them despite professional representation and multiple opportunities.

Facts

The claimant was a support worker for Bolton Cares who brought claims including constructive dismissal and Working Time Regulations breaches spanning January 2020 to May 2023. She alleged being required to work excessive hours without breaks, being unable to leave at end of shifts due to lack of cover, and being refused rest breaks. Despite being professionally represented throughout and over 14 months since case management directions, the claimant failed to provide necessary particulars of her allegations including specific dates, who was responsible, and extent of hours worked.

Decision

The tribunal struck out four specific allegations (6(c), 6(d), 6(m) and the entire Working Time Regulations claim at allegation 28) on three grounds: no reasonable prospects of success, failure to comply with tribunal orders, and unreasonable conduct. The claimant's representative repeatedly failed to provide required particulars despite multiple requests from the respondent and tribunal directions, instead sending spreadsheets with unexplained dates that included days the claimant was on leave or worked insufficient hours.

Practical note

Professional representatives must comply with tribunal directions to particularise claims with specific dates and details - repeatedly sending ambiguous spreadsheets without narrative, expecting the respondent to decipher the claim, constitutes deliberate and persistent unreasonable conduct justifying strike out even before trial.

Legal authorities cited

Harris v Academies Enterprise Trust [2015] IRLR 208Smith v Tesco Stores Ltd [2023] EAT 11Governing Body of St Albans Girls' School v Neary [2009] EWCA Civ 1190Bolch v Chipman [2004] IRLR 140Blockbuster Entertainment Ltd v James [2006] IRLR 630Arrow Nominees v Blackledge [2000] 2 BCLC 167Emuemukoro v Croma Vigilant (Scotland) Ltd 2022 ICR 327Weir Valves & Controls (UK) Ltd v Armitage [2004] ICR 371

Statutes

Employment Tribunal Rules of Procedure 2024 Rule 3Employment Tribunal Rules of Procedure 2024 Rule 38Working Time Regulations 1998 Regulation 12(1)

Case details

Case number
2410287/2023
Decision date
28 May 2025
Hearing type
strike out
Hearing days
1
Classification
procedural

Respondent

Sector
healthcare
Represented
Yes
Rep type
barrister

Employment details

Role
Support Worker

Claimant representation

Represented
No