Cases2207192/2020

Claimant v Leather Inside Out

27 March 2025Before Employment Judge Jonathan GidneyLondon Centralin person

Outcome

Claimant fails

Individual claims

Whistleblowingfailed

The tribunal found that the claimant made 3 qualifying protected disclosures (PIDs 6, 8 and 9) but that the two detriments complained of were not done on the ground that he made those disclosures. The first detriment (claiming he was not an employee) was a legitimate defence based on the fact he was paid gross without PAYE deductions. The second detriment (refusing SARs) was done for reasons stated in the refusal letters: prevention/detection of crime and that requests were manifestly unfounded/excessive, based on the claimant having stolen the respondent's hard drives.

Automatic Unfair Dismissalstruck out

Struck out at an earlier preliminary hearing by Employment Judge Beyzade on 19 April 2022 on the grounds that the claim was not well founded

Direct Discrimination(sex)struck out

Struck out at an earlier preliminary hearing by Employment Judge Beyzade on 19 April 2022 on the grounds that the claim was not well founded

Direct Discrimination(race)struck out

Struck out at an earlier preliminary hearing by Employment Judge Beyzade on 19 April 2022 on the grounds that the claim was not well founded

Harassmentstruck out

Struck out at an earlier preliminary hearing by Employment Judge Beyzade on 19 April 2022 on the grounds that the claim was not well founded

Facts

The claimant was engaged by a charity providing training and employment for ex-offenders for six months from June to December 2019. He was dismissed for breakdown in trust and confidence. The claimant alleged he made multiple whistleblowing disclosures about tax non-payment, theft, fraud and money laundering. He claimed two detriments: that the respondent falsely claimed he was not an employee, and that the respondent refused two subject access requests. The respondent did not attend the hearing and had applied to be wound up.

Decision

The tribunal found that only 3 of 8 alleged protected disclosures qualified for protection under the ERA 1996. However, both alleged detriments were not done on the ground of the protected disclosures. The employment status defence was based on genuine belief the claimant was a contractor (paid gross without PAYE). The SAR refusals were justified by the claimant having stolen the respondent's hard drives and legitimate data protection exemptions applied. All claims dismissed.

Practical note

Even where qualifying protected disclosures are established, a whistleblowing detriment claim will fail if the employer can show the detrimental acts had other legitimate explanations unconnected to the disclosures, particularly where the claimant's own conduct (such as theft of company property) provides the real reason for the treatment.

Legal authorities cited

Cavendish Munro Professional Risks Management Ltd v Geduld [2010] ICR 325Onyango v Berkley Solicitors [2013] IRLR 338Korashi v Abertawe Bro Morgannwg University Local Health Board [2012] IRLR 4Simpson v Cantor Fitzgerald Europe [2021] IRLR 238Williams v Michelle Brown AM [2019] UKEAT/0044/19Kilraine v London Borough of Wandsworth [2018] ICR 1850Millbank Financial Services Ltd v Crawford [2014] IRLR 18Norbrook Laboratories (GB) Ltd v Shaw [2014] ICR 540Eiger Securities LLP v Korshunova [2017] IRLR 115Kraus v Penna Plc [2004] IRLR 260Blackbay Ventures Ltd v Gahir [2014] IRLR 416Fecit & Others v NHS Manchester [2011] IRLR 111London Borough of Harrow v Knight [2003] IRLR 140Jesudason v Alder Hay Childrens NHS Foundation Trust [2020] IRLR 374Timis v Osipov [2019] IRLR 52

Statutes

ERA 1996 s.230EqA 2010 s.13EqA 2010 s.26Theft Act 1968 s.1Fraud Act 2006 s.2Proceeds of Crime Act 2002 s.327Data Protection Act 2018 Sch 2, Part 1, Paragraph 2Data Protection Act 2018 Part 3 s.53ERA 1996 s.103AERA 1996 s.47B

Case details

Case number
2207192/2020
Decision date
27 March 2025
Hearing type
full merits
Hearing days
2
Classification
contested

Respondent

Sector
charity
Represented
No

Employment details

Service
6 months

Claimant representation

Represented
No