Cases3307778/2024

Claimant v Arrivia Europe Ltd

24 April 2025Before Employment Judge Andrew Clarke KCWatfordremote video

Outcome

Other

Individual claims

Unfair Dismissalnot determined

This is a preliminary hearing on a deposit order application only. The substantive claim for ordinary unfair dismissal has not yet been determined and will proceed to full hearing.

Automatic Unfair Dismissalnot determined

The tribunal found the claimant's case had more than little reasonable prospect of success. The respondent's deposit order application was dismissed. Causation and whether the protected disclosure was the principal reason for dismissal remain to be determined at full hearing.

Detrimentnot determined

The detriment alleged is the disciplinary process initiated on 1 March 2024. The tribunal found the claim had realistic prospects given the chronology (disclosure on 27 February, investigation commenced 1 March). The deposit order application was dismissed and causation will be determined at full hearing.

Facts

The claimant, a 7-year employee, was dismissed on 9 April 2024 following a disciplinary process begun on 1 March 2024. On 27 February 2024, in a 58-minute phone call, he disclosed to the Chief Experience Officer that his manager had made 'spiff payments' to agents (overpaying expenses and receiving kickbacks) when she was a sales supervisor. The respondent knew before this disclosure about the claimant's contact with a former competitor and conduct issues from November 2023, but commenced disciplinary investigation shortly after the 27 February disclosure.

Decision

The tribunal dismissed the respondent's application for deposit orders against the whistleblowing claims. The judge found the claims had realistic prospects of success and could not be said to have little reasonable prospect. Whether the communication constituted a disclosure of 'information', whether it was in the public interest, and causation all required determination at full hearing after hearing evidence.

Practical note

Deposit order applications in whistleblowing cases face a high bar where there is a prima facie chronology linking disclosure to detriment/dismissal, even where the respondent has alternative explanations for dismissal.

Legal authorities cited

Kilraine v London Borough of Wandsworth [2018] ICR 1850Hemdan v Ishmail [2017] IRLR 228Van Rensburg v Royal Borough of Kingston-upon-Thames [2007] All ER (D) 187Amber v West Yorkshire Fire and Rescue Service [2025] ICR 228Cox v Adecco [2021] ICR 130Chesterton Global Ltd v Nurmohamed [2018] ICR 731

Statutes

ERA 1996 s.43BERA 1996 s.47BERA 1996 s.103A

Case details

Case number
3307778/2024
Decision date
24 April 2025
Hearing type
preliminary
Hearing days
1
Classification
contested

Respondent

Sector
technology
Represented
Yes
Rep type
barrister

Employment details

Service
7 years

Claimant representation

Represented
Yes
Rep type
barrister