Cases3305333/2024

Claimant v Keyloop (UK) Limited

27 May 2025Before Employment Judge GrahamBury St Edmundsin person

Outcome

Partly successful

Individual claims

Constructive Dismissalnot determined

This is a preliminary hearing dealing with the admissibility of without prejudice communications. The tribunal struck out two of the victimisation claims (15c and 15d) but the underlying constructive dismissal claim remains to be determined at a full hearing.

Unfair Dismissalnot determined

This claim remains to be determined at a full merits hearing. The preliminary hearing addressed only whether certain settlement discussions could be admitted as evidence.

Direct Discrimination(sex)not determined

The sex discrimination claim remains to be determined at a full merits hearing. No determination was made on the merits of this claim.

Harassment(sex)not determined

The harassment claim remains to be determined at a full merits hearing. The preliminary hearing did not address the merits of this claim.

Victimisationpartly succeeded

The tribunal struck out victimisation claims at issues 15(c) and 15(d) on the basis they had no reasonable prospects of success, as they relied on without prejudice communications from 4 January 2024 and March/April 2024. The tribunal found the without prejudice rule applied and the exception for unambiguous impropriety was not met. Other victimisation claims may remain.

Facts

The claimant was employed from 2003 and promoted to Global Head of Professional Services in September 2022. In January 2024, the CEO (second respondent) informed her she would be replaced and offered her a demotion to Senior Vice President or a settlement package. She resigned on 9 January 2024 alleging sex discrimination. Settlement negotiations continued into April 2024, with the respondent's offer becoming considerably less generous after the claimant notified ACAS of a discrimination claim. The claimant brought claims of constructive dismissal, discrimination, harassment and victimisation.

Decision

The tribunal held that the settlement offer of 4 January 2024 was protected by the without prejudice rule, as there was a potential dispute that the respondent reasonably anticipated might lead to litigation. The tribunal found the exception for unambiguous impropriety did not apply, as the claimant had not demonstrated a clear case of discrimination or victimisation — a bare allegation was insufficient. Two victimisation claims (15c and 15d) relying on the without prejudice communications were struck out for having no reasonable prospects of success.

Practical note

A bare allegation of discrimination or victimisation is insufficient to disapply the without prejudice rule; the exception for unambiguous impropriety requires a clear case of discriminatory conduct, not merely an assertion that settlement offers were discriminatory.

Legal authorities cited

Woodward v Santander UK Plc [2010] IRLR 834Anyanwu v South Bank Students Union and South Bank University [2001] IRLR 305Jones v Tower Boot [1997] IRLR 168Harrison v Aryma Ltd [2019] UKEAT/0085/19/JOJBNP Paribas v Mezzotero [2004] IRLR 509Cutts v Head [1984] Ch. 290Unilever PLC v The Proctor and Gamble Co [2000] 1 WLR 2436Rush v Tompkins Ltd [1989] AC 1280Barnetson v Framlington Group Ltd [2007] ICR 1439BE v DE [2014] EWCA 2318 (Fam)Portnykh v Normura International plc [2014] IRLR 259Avonwick Holdings Limited v Webinvest [2014]Motorola Solutions Inc v Hytera Communications Corp Ltd [2021] EWCA Civ 11

Statutes

Rule 52 Employment Tribunal Rules of Procedure 2024Rule 38 Employment Tribunal Rules of Procedure 2024Section 136 Equality Act 2010Section 111A Employment Rights Act 1996

Case details

Case number
3305333/2024
Decision date
27 May 2025
Hearing type
preliminary
Hearing days
1
Classification
contested

Respondent

Sector
technology
Represented
Yes
Rep type
barrister

Employment details

Role
Global Head of Professional Services
Service
21 years

Claimant representation

Represented
Yes
Rep type
barrister