Cases2303036/2024

Claimant v Katie Smith t/a St. Peter's Playgroup

25 April 2025Before Employment Judge Sarah BowenLondon Southremote video

Outcome

Partly successful£17,167

Individual claims

Wrongful Dismissalsucceeded

All five claimants succeeded in their wrongful dismissal claims. The tribunal found that each was dismissed without proper notice, awarding damages calculated on gross pay to reflect tax treatment as post-employment notice pay.

Unlawful Deduction from Wagessucceeded

All five claimants succeeded in their holiday pay claims for accrued but unpaid holiday at termination. The respondent had made unauthorised deductions from wages in respect of outstanding holiday pay owed at dismissal.

Holiday Payfailed

All claims for historic holiday pay covering the 2 years preceding dismissal under the Working Time Regulations failed and were dismissed. The tribunal did not find in favour of backdated holiday pay claims.

Unfair Dismissalpartly succeeded

Three claimants (Reeves, McGow, Ford, Hughes) succeeded in unfair dismissal claims as they had sufficient service. One claimant (Tabi) failed as she did not have 2 years' continuous service. For Reeves, despite succeeding on unfair dismissal, there was a 100% Polkey reduction as she would have been fairly dismissed anyway.

Redundancy Paypartly succeeded

Four claimants (Reeves, McGow, Ford, Hughes) were entitled to statutory redundancy payments as they were dismissed by reason of redundancy and had sufficient service. One claimant (Tabi) was not entitled as she lacked 2 years' continuous service.

Facts

Five employees of St. Peter's Playgroup brought claims after dismissal by the owner Katie Smith. The playgroup appears to have ceased trading, with a corporate recovery director (Mr Beck from Cranbrook Corporate Recovery Limited) assisting at the hearing. All claimants were dismissed without proper notice and with outstanding holiday pay. Four had sufficient service for unfair dismissal and redundancy claims, while one (Tabi) had under 2 years' service.

Decision

The tribunal found all claimants were dismissed in breach of contract and entitled to notice pay and accrued holiday pay. Four claimants succeeded in unfair dismissal claims and were awarded statutory redundancy payments, though Carly Reeves received a 100% Polkey reduction. Claims for historic holiday pay failed for all claimants. One claimant failed on unfair dismissal and redundancy due to insufficient service.

Practical note

Even where unfair dismissal is established, a 100% Polkey reduction will eliminate any compensatory award if dismissal was inevitable, though statutory redundancy payments and contractual entitlements remain payable.

Award breakdown

Notice pay£7,256
Holiday pay£257
Redundancy pay£9,655

Adjustments

Polkey reduction100%

For claimant Carly Reeves, tribunal found 100% chance she would have been fairly dismissed in any event, meaning no compensatory award despite succeeding on unfair dismissal

Legal authorities cited

Statutes

ERA 1996 s.163

Case details

Case number
2303036/2024
Decision date
25 April 2025
Hearing type
full merits
Hearing days
3
Classification
contested

Respondent

Sector
education
Represented
No

Claimant representation

Represented
No