Cases2214947/2023

Claimant v V & A Enterprises Limited

24 March 2025Before Employment Judge GoodmanLondon Centralhybrid

Outcome

Claimant succeeds

Individual claims

Unfair Dismissalsucceeded

The tribunal found that no reasonable employer would have dismissed without first attempting mediation, a behaviour agreement, or issuing a final warning, given the claimant's depression, good work record, and the fact the conflict was limited to one ex-partner colleague. Dismissal was outside the band of reasonable responses.

Discrimination Arising from Disability (s.15)(disability)succeeded

The tribunal found the claimant was dismissed because of conduct arising from her disability (depression and autism spectrum disorder). The respondent knew or should have known about the disability and its impact. Dismissal was not a proportionate means of achieving the legitimate aim of protecting staff, as mediation or a final warning would have been more appropriate alternatives.

Wrongful Dismissalsucceeded

The tribunal concluded that while there was misconduct, it was not so serious as to constitute a fundamental breach of contract justifying summary dismissal. The claimant was entitled to notice of dismissal.

Facts

The claimant, a museum technician with depression and undiagnosed autism, was dismissed for gross misconduct after complaints from a former romantic partner (K) that she was being stalked and bullied. The conduct included excessive emails, visiting K's workspace, using corridors and toilets near K, and booking a specialist conference K would attend. The claimant had been instructed to limit contact but struggled to understand or implement the required boundaries. She was suspended in July 2022, investigated, and dismissed without notice in April 2023. The claimant had a good work record and colleagues noted she was literal-minded and struggled with social cues.

Decision

The tribunal found the dismissal was unfair, discriminatory under s.15 Equality Act 2010, and wrongful. The respondent knew or should have known the claimant's conduct arose from disability (depression and autism). No reasonable employer would have dismissed without attempting mediation, a behaviour agreement, or a final warning. The tribunal reduced awards by 25% (majority) reflecting the risk the claimant would have been dismissed anyway due to potential continued non-compliance.

Practical note

Employers must explore alternatives to dismissal (mediation, behaviour agreements, warnings) where conduct arises from disability, especially when the employee has a good work record and the conflict involves one colleague; dismissal without such steps will be unfair and discriminatory even where conduct is serious.

Adjustments

Polkey reduction25%

By majority (Employment Judge and Mr Godecharle), 25% reduction for risk claimant would have been dismissed anyway even with fair procedures due to potential continued disobedience. Ms Breslin assessed 20%.

Legal authorities cited

McNicol v Balfour Beatty Rail Maintenance Ltd [2002] ICR 1498Sainsbury's Supermarkets Ltd v Hitt [2003] ICR 111BHS v Burchell [1978] IRLR 379Chagger v Abbey National Plc [2010] ICR 397Polkey v A E Dayton Services Ltd [1988] ICR 142York City Council v Grosset [2018] ICR 1492A Ltd v Z [2020] ICR 99Donelien v Liberata UK Limited [2018] EWCA Civ 129

Statutes

Equality Act 2010 s.6Equality Act 2010 s.15Employment Rights Act 1996 s.123(6)Employment Rights Act 1996 s.122(2)Employment Rights Act 1996 s.98

Case details

Case number
2214947/2023
Decision date
24 March 2025
Hearing type
full merits
Hearing days
4
Classification
contested

Respondent

Sector
public sector
Represented
Yes
Rep type
barrister

Employment details

Role
Museum Technician
Service
7 years

Claimant representation

Represented
Yes
Rep type
barrister