Cases1401274/2024

Claimant v Atlantic Laundry Limited

15 April 2025Before Employment Judge N J Roperremote video

Outcome

Claimant succeeds£3,461

Individual claims

Unfair Dismissalsucceeded

The tribunal found that even bearing in mind the respondent was a small employer facing immediate and significant business difficulty, there was a complete absence of any effective consultation process. The decision to dismiss the claimants summarily was not within the band of reasonable responses and was not fair and reasonable in all the circumstances.

Redundancy Paysucceeded

The claimants were clearly dismissed by reason of redundancy and the statutory definition in section 139 of the Employment Rights Act 1996 was met. The respondent no longer needed supervisors after the loss of the Sykes Cottages contract which accounted for 85% of turnover.

Facts

Two supervisors, Mr and Mrs Iliev, were employed by a commercial laundry company which lost its major customer (Sykes Cottages) accounting for 85% of turnover. On 4 March 2024, they were called into the office on a non-working day and summarily dismissed for redundancy with immediate effect without any prior consultation. Both were paid notice and holiday pay but not redundancy pay. Mr Iliev found new work within two weeks, while Mrs Ilieva underwent emergency surgery in Bulgaria and found work in summer 2024.

Decision

The tribunal found the dismissals were by reason of redundancy and awarded statutory redundancy payments of £1,644.21 each. However, the dismissals were unfair due to the complete absence of consultation. The tribunal applied a Polkey reduction, limiting compensation to three weeks' net pay (£1,316.76) plus £500 for loss of statutory rights, as fair dismissals would have occurred within three weeks had proper consultation taken place.

Practical note

Even small employers facing urgent business crises must undertake some consultation before redundancy dismissals, though Polkey reductions may significantly limit compensation where fair dismissal would have occurred shortly afterwards in any event.

Award breakdown

Compensatory award£1,817
Redundancy pay£1,644
Loss of statutory rights£500

Award equivalent: 6.3 weeks' gross pay

Legal authorities cited

Polkey v A E Dayton Services Ltd [1988] ICR 142Safeway Stores Plc v Burrell [1997] ICR 523Williams v Compair Maxam [1982] ICR 156Langston v Cranfield University [1998] IRLR 172Osinuga v BPP University Legal Team [2022] EAT 53Haycocks v ADP Pro UK Ltd [2024] EWCA 1291

Statutes

ERA 1996 s.98(4)ERA 1996 s.98(2)(c)ERA 1996 s.139

Case details

Case number
1401274/2024
Decision date
15 April 2025
Hearing type
full merits
Hearing days
2
Classification
contested

Respondent

Sector
other
Represented
No
Rep type
in house

Employment details

Role
Supervisor
Salary band
£25,000–£30,000
Service
3 years

Claimant representation

Represented
No