Cases1304779/2023

Claimant v Busy Bears Nursery Limited

4 April 2025Before Employment Judge G SmartMidlands Westremote video

Outcome

Claimant succeeds

Individual claims

Wrongful Dismissalsucceeded

The tribunal found the respondent failed to prove that the claimant's conduct justified summary dismissal. The respondent alleged gross misconduct relating to child protection, safeguarding, and regulatory breaches but provided no documentary evidence to support the allegations. Without corroborating evidence, the respondent did not discharge its burden of proof that the allegations were factually made out or that they amounted to gross misconduct justifying summary termination.

Holiday Paysucceeded

The tribunal found the claimant was entitled to accrued but unpaid holiday pay that would have arisen during the three-month notice period she was contractually entitled to. As the wrongful dismissal claim succeeded, the respondent was obliged to pay for statutory annual leave that would have accrued during the notice period.

Facts

The claimant was promoted to Nursery Manager in September 2022 and passed her probationary period in March 2023 with positive feedback. In April 2023, the respondent received an anonymous whistleblowing letter from Ofsted raising concerns about the nursery. On 4 April 2023, the claimant was dismissed on three months' notice. On 11 April 2023, after conducting a review of the nursery, the respondent summarily dismissed the claimant alleging gross misconduct relating to safeguarding, regulatory compliance, and falsification of records. The claimant was provided with no documentary evidence supporting the allegations and was not given an opportunity to respond to them properly.

Decision

The tribunal found the claims for wrongful dismissal and holiday pay succeeded. The respondent failed to discharge its burden of proving the allegations of gross misconduct were factually made out, providing no documentary evidence to support them. The tribunal found the respondent deliberately withheld disclosure and had only paid lip service to the tribunal's case management orders. The claimant was entitled to damages for breach of contract representing her three-month notice period and accrued annual leave. Remedy was adjourned for calculation after consideration of mitigation and ACAS Code breaches.

Practical note

Employers must provide cogent documentary evidence to prove gross misconduct allegations when seeking to justify summary dismissal; mere assertion is insufficient to discharge the burden of proof, even where after-discovered misconduct is legally permissible as a defence.

Legal authorities cited

Cavenagh v William Evans Ltd [2013] 1 WLR 238Mbubaegbu v Homerton University Hospital NHS Foundation Trust UKEAT/0218/17Williams v Leeds United Football Club [2015] IRLR 383Hadley v Baxendale (1854) 9 Exch. 341Galoo Limited v Bright Grahame Murray [1994] WLR 1360Johnson v Unisys Ltd [2001] UKHL 13Hovis Limited v Louton [2021] UKEAT/1023/20/LABriscoe v Lubrizol Limited [2002] EWCA Civ 508Dunn and Davidson v AAH Limited [2010] EWCA Civ 183Palmeri v Charles Stanley & Co Limited [2021] IRLR 563 (HC)Laws v London Chronicle [1959] 1 WLR 698Neary v Dean of Westminster [1999] IRLR 288Boston Deep Sea Fishing v Ansell (1888) 39 Ch D 339

Statutes

Working Time Regulations 1998 reg 30Working Time Regulations 1998 reg 14(2)Employment Tribunals Extension of Jurisdiction (England and Wales) Order 1994

Case details

Case number
1304779/2023
Decision date
4 April 2025
Hearing type
full merits
Hearing days
1
Classification
contested

Respondent

Sector
education
Represented
No
Rep type
in house

Employment details

Role
Nursery Manager
Service
10 months

Claimant representation

Represented
No