Cases3311189/2024

Claimant v Specialised Management Services Limited (In Administration)

26 March 2025Before Regional Employment Judge FoxwellEast of Englandon papers

Outcome

Claimant succeeds

Individual claims

Failure to Inform & Consultsucceeded

The respondent failed to comply with section 188 TULRCA 1992 by dismissing 20 or more employees for redundancy on or after 24 July 2024 without any consultation with employee representatives, where there was no recognised trade union or elected employee representatives at the establishment.

Facts

47 claimants were employed at Specialised Management Services Limited's establishment in Great Yarmouth. On or after 24 July 2024, 20 or more employees were made redundant, with the last dismissal occurring on 13 September 2024. The employer, which is now in administration, failed to consult with employee representatives before making the redundancies, despite there being no recognised trade union or elected representatives at the establishment.

Decision

The tribunal found the respondent breached section 188 TULRCA 1992 by failing to consult on collective redundancies. A protective award was granted for the maximum 90-day period beginning 24 July 2024, reflecting the punitive nature of such awards where no mitigating circumstances exist. The recoupment regulations apply.

Practical note

Employers in administration must still comply with collective consultation obligations under TULRCA 1992, and failure to do so will result in maximum 90-day protective awards absent exceptional circumstances.

Legal authorities cited

Statutes

Trade Union and Labour Relations (Consolidation) Act 1992 s.188Trade Union and Labour Relations (Consolidation) Act 1992 s.189(5)(b)

Case details

Case number
3311189/2024
Decision date
26 March 2025
Hearing type
on papers
Hearing days
Classification
procedural

Respondent

Sector
professional services
Represented
No

Claimant representation

Represented
No