Cases3311176/2023

Claimant v IWL Realisations 2023 Ltd (in administration)

8 May 2025Before Employment Judge HawksworthEast of Englandon papers

Outcome

Claimant succeeds

Individual claims

Failure to Inform & Consultsucceeded

The respondent made 20 or more employees redundant at the establishment on or within 90 days of 6 July 2023 without any consultation having taken place. This was in breach of section 188 of the Trade Union and Labour Relations (Consolidation) Act 1992, which requires collective consultation before redundancies.

Facts

The claimant was employed at the respondent's Peterborough establishment and made redundant on 6 July 2023. The respondent made 20 or more employees redundant at that establishment within a 90-day period. The claimant was dismissed without any consultation. There was no recognised trade union or elected employee representative in place. The first respondent entered administration and did not present a response, though administrators consented to the claim proceeding.

Decision

The tribunal found the claim well-founded as the respondent breached section 188 of TULR(C)A 1992 by failing to consult before making collective redundancies. A protective award of the maximum 90 days remuneration was ordered, beginning from the dismissal date, as there were no circumstances making it unjust to award the maximum period. The decision was made on the papers without a hearing.

Practical note

Where an insolvent employer fails to conduct collective consultation before redundancies, tribunals will award the maximum 90-day protective award on the papers unless there are mitigating circumstances.

Legal authorities cited

Statutes

TULR(C)A 1992 s.188TULR(C)A 1992 s.189(3)Employment Protection (Recoupment of Jobseeker's Allowance and Income Support) Regulations 1996

Case details

Case number
3311176/2023
Decision date
8 May 2025
Hearing type
default judgment
Hearing days
Classification
default

Respondent

Sector
other
Represented
No

Claimant representation

Represented
No