Cases8001076/2024

Claimant v D R Collin & Son Ltd

22 April 2025Before Employment Judge Michelle SutherlandScotlandin person

Outcome

Claimant fails

Individual claims

Automatic Unfair Dismissalfailed

The tribunal found that the principal reason for dismissal was the downturn in work, the claimant's short length of service, and the fact he did not do international deliveries. The tribunal concluded the alleged protected disclosures on 12 and 15 April 2024 were not the reason for dismissal. The disclosure on 12 April about not receiving training on covering shellfish was not a protected disclosure because the claimant did not reasonably believe it showed endangerment to health and safety and it was not made in the public interest. The disclosure on 15 April about the accident was a protected disclosure, but the tribunal found it did not operate on the mind of the decision-maker when dismissing the claimant.

Facts

The claimant, an experienced driver aged 59, was employed by a fish and shellfish wholesaler. On 12 April 2024, the Managing Director told him shellfish should always be covered during transport. The claimant responded defensively, stating he had not been trained on this. On 15 April 2024, the claimant slipped entering a van and sustained a head injury requiring two weeks off work. He was dismissed on 1 May 2024 due to a downturn in work, having been employed for approximately 9 months in his second period of employment. The claimant claimed his dismissal was because he made protected disclosures about health and safety.

Decision

The tribunal found that the claimant did not make protected disclosures on 12 April 2024 as alleged. The tribunal found that the disclosure on 15 April 2024 about his work accident was a protected disclosure, but that it was not the reason for dismissal. The principal reason for dismissal was the downturn in work, his short length of service, and the fact he did not perform international deliveries. The claim for automatic unfair dismissal was dismissed.

Practical note

An employer can successfully defend an automatic unfair dismissal claim following a genuine protected disclosure if it can demonstrate that a legitimate business reason (such as redundancy due to downturn in work) was the principal reason for dismissal, not the disclosure itself.

Legal authorities cited

Cavendish Munro Professional Risks Management Ltd v Geduld [2010] ICR 325Kilraine v Wandsworth London Borough Council [2018] ICR 1850Chesterton Global Ltd v Nurmohamed [2018] ICR 731Royal Mail Group Ltd v Jhuti [2020] ICR 731Abernethy v Mott, Hay and Anderson [1974] ICR 323

Statutes

Reporting of Injuries, Diseases and Dangerous Occurrences Regulations 2013 (RIDDOR)Employment Rights Act 1996 s.103AEmployment Rights Act 1996 s.43AEmployment Rights Act 1996 s.43BEmployment Rights Act 1996 s.43CEmployment Rights Act 1996 s.43F

Case details

Case number
8001076/2024
Decision date
22 April 2025
Hearing type
full merits
Hearing days
3
Classification
contested

Respondent

Sector
wholesale distribution fish
Represented
Yes
Rep type
solicitor

Employment details

Role
Driver
Salary band
£30,000–£40,000
Service
9 months

Claimant representation

Represented
Yes
Rep type
solicitor