Cases2219596/2024

Claimant v Pharma& UK Limited

4 April 2025Before Employment Judge WoodheadLondon Centralin person

Outcome

Claimant fails

Individual claims

Failure to Inform & Consultfailed

The claim was dismissed on two grounds: firstly, the Respondent as transferee could not be liable for the obligation to inform and consult, and could not be jointly and severally liable as the claim was not brought against the transferor; secondly, the complaint was presented out of time when it was reasonably practicable to present it in time.

Automatic Unfair Dismissalfailed

The tribunal found the complaint of automatic unfair dismissal pursuant to Section 103A ERA (whistleblowing/protected disclosure) was not well-founded and dismissed it.

Facts

The claimant brought claims relating to a TUPE transfer against the transferee employer. She complained of failure to inform and consult under TUPE and automatic unfair dismissal for making protected disclosures. The case involved a business transfer where the claimant alleged the respondent failed to comply with consultation obligations.

Decision

The tribunal dismissed both claims. The TUPE consultation claim failed because the respondent as transferee had no liability for consultation obligations and because the claim was presented out of time when it was reasonably practicable to present it in time. The whistleblowing dismissal claim was found not well-founded.

Practical note

Claims for failure to inform and consult under TUPE must be brought against the correct party (usually the transferor) and within strict time limits, and transferees cannot be held liable unless the transferor is also a party to proceedings.

Legal authorities cited

Statutes

ERA 1996 s.103ATUPE Regulation 13TUPE Regulation 13A

Case details

Case number
2219596/2024
Decision date
4 April 2025
Hearing type
full merits
Hearing days
3
Classification
contested

Respondent

Sector
healthcare
Represented
Yes
Rep type
barrister

Claimant representation

Represented
No