Cases8000958/2025

Claimant v Love @ Care Ltd

13 May 2025Before Employment Judge J McCluskeyScotlandin person

Outcome

Other

Individual claims

Whistleblowingnot determined

Interim relief application refused. Tribunal found claimant likely to establish protected disclosure to employer on 26 January 2025 regarding national minimum wage breach. However, tribunal could not determine likelihood of success on whether disclosure to Fife Council on 7 February 2025 was protected. Most critically, tribunal found claimant did not have sufficiently high likelihood of proving whistleblowing was reason for dismissal, given existence of independent investigation into incident with client LB on 17 February 2025, external HR report recommending disciplinary hearing, and dismissal reasons matching investigation report allegations rather than protected disclosures.

Facts

Claimant was an adult social care worker employed from December 2024 to April 2025. She raised a grievance on 26 January 2025 about unpaid working hours and national minimum wage breaches. After her grievance was rejected, she submitted a Social Care Complaint to Fife Council on 7 February 2025. On 17 February 2025, an incident occurred involving a client (LB) while claimant was providing care. An external HR investigation followed, and claimant was dismissed on 15 April 2025 for gross misconduct relating to the client incident, without a disciplinary hearing being held.

Decision

The tribunal refused the interim relief application. While the claimant was likely to establish her grievance to her employer about minimum wage was a protected disclosure, the tribunal could not determine likelihood of success on whether her complaint to Fife Council was protected. Critically, the tribunal found insufficient likelihood the protected disclosure was the reason for dismissal, given the independent investigation into the client incident and that dismissal reasons matched the investigation report allegations.

Practical note

Interim relief applications in whistleblowing cases face significant hurdles where there is evidence of an independent reason for dismissal, particularly when an external investigation recommends disciplinary action matching the stated dismissal reasons.

Legal authorities cited

Kilraine v London Borough of Wandsworth [2018] ICR 1850Taplin v C Shippam Ltd [1978] IRLR 450Ministry of Justice v Sarfraz [2011] IRLR 562Al Qasimi v Robinson EAT 0283/17Simpson v Cantor Fitzgerald Europe [2020] ICR 236Chesterton Global

Statutes

ERA 1996 s.43AERA 1996 s.43BERA 1996 s.43GERA 1996 s.43CNational Minimum Wage Act 1998ERA 1996 s.103AERA 1996 s.128ERA 1996 s.129

Case details

Case number
8000958/2025
Decision date
13 May 2025
Hearing type
interim relief
Hearing days
1
Classification
contested

Respondent

Sector
healthcare
Represented
Yes
Rep type
lay rep

Employment details

Role
adult social care worker
Service
4 months

Claimant representation

Represented
Yes
Rep type
lay rep