Cases6010533/2025

Claimant v Force Contracting Services Ltd

12 April 2025Before Employment Judge L BrownNottinghamin person

Outcome

Other

Individual claims

Automatic Unfair Dismissalnot determined

Interim relief application refused. Tribunal found claimant had 'pretty good chance' of establishing five separate protected disclosures, but did not have a pretty good chance of establishing causation — that the disclosures were the reason or principal reason for dismissal. Investigation began 12 February 2025, before most disclosures made, and disciplinary process already underway before later disclosures.

Whistleblowingnot determined

Claimant alleged five protected disclosures: (1) concerns about GT's threatening behaviour endangering health/safety; (2) repeated concerns at meeting; (3) allegations of fraud via false compensation events; (4) further fraud allegations without detail; (5) specific fraud allegations by email. Tribunal found first three likely to be protected disclosures but causation not established. Disclosure 4 was allegation not information. Disclosure 5 not yet part of claim.

Facts

Claimant was a quantity surveyor dismissed following an altercation on 11 February 2025 with colleague GT, who allegedly used threatening behaviour and racially abusive language. Claimant was dismissed; GT received a warning and probation extension. Following the incident, claimant raised grievances about feeling unsafe due to GT's behaviour and made allegations of fraudulent activity by the company through false compensation events and bribery. Respondent commenced investigation on 12 February 2025, before most of the alleged disclosures were made.

Decision

Tribunal refused interim relief application. While the judge found claimant had a 'pretty good chance' of establishing that some communications were protected disclosures (particularly concerns about GT's behaviour endangering health and safety, and allegations of fraud), the claimant did not have a pretty good chance of proving causation — that the disclosures were the reason or principal reason for dismissal, as the investigation and disciplinary process had commenced before most disclosures were made.

Practical note

Interim relief applications fail on causation where investigation and disciplinary process commenced before protected disclosures were made, even where disclosures themselves meet the statutory test.

Legal authorities cited

Cavendish Munro Professional Risks Management Ltd v Geduld [2010] ICR 325Williams v Michelle Brown AM UKEAT0044/19/00Darnton v University of Surrey [2003] IRLR 133Korashi v Abertawe Bro Morgannwg University Local Health Board [2012] IRLR 4Eiger Securities LLP v Korshunova [2017] ICR 561Royal Mail v Jhuti [2019] UKSC 55Fincham v HM Prison Service EAT 0925/01Simpson v Cantor Fitzgerald Europe [2020] EWCA Civ 1601Dandpat v The University of Bath UKEAT/0408/09London City Airport Ltd v Chacko [2013] IRLR 610Chesterton Global Ltd v Nurmohamed [2018] ICR 731Kuzel v Roche Products Ltd [2008] ICR 799Taplin v Shippam Ltd [1978] ICR 1068Ministry of Justice v Sarfraz [2011] IRLR 562Kilraine v London Borough of Wandsworth [2018] ICR 1850

Statutes

ERA 1996 s.103AERA 1996 s.128ERA 1996 s.129ERA 1996 s.43BERA 1996 s.43C

Case details

Case number
6010533/2025
Decision date
12 April 2025
Hearing type
interim
Hearing days
1
Classification
contested

Respondent

Sector
construction
Represented
Yes
Rep type
solicitor

Employment details

Role
quantity surveyor

Claimant representation

Represented
No