Cases4106811/2024

Claimant v Church of Scotland Central Services Committee

21 March 2025Before Employment Judge S MacLeanScotlandremote video

Outcome

Other

Individual claims

Unfair Dismissalnot determined

Respondent applied to strike out the claim arguing claimant had resigned. Judge found core disputed facts as to whether there was express dismissal or constructive dismissal dependent on evidence at final hearing. Strike out application refused as test not met.

Victimisationnot determined

Respondent argued protected act not established (complaint in December 2022). Judge found sufficient detail provided to meet test on strike out, with core disputed fact as to reason for treatment. Evidence at full hearing required.

Direct Discrimination(pregnancy)not determined

Claim proceeded to final hearing. No strike out or deposit order application determined in relation to this claim at this preliminary hearing.

Unlawful Deduction from Wagesnot determined

Claim proceeded to final hearing. No strike out or deposit order application determined in relation to this claim at this preliminary hearing.

Facts

Claimant worked for Church of Scotland and took maternity leave. In June 2024, through Citizens Advice Bureau adviser, she sought release from employment. Parties discussed offsetting contractual maternity pay repayment (£5,934.42) against accrued holiday pay. Agreement in principle reached on 27 June 2024 but settlement agreement not completed due to dispute over payment of legal costs. Respondent issued letter on 15 July 2024 headed 'Notice of Resignation' stating employment would terminate on 26 July 2024. Claimant denied resigning and brought claims including unfair dismissal and victimisation.

Decision

Judge refused respondent's applications to strike out unfair dismissal and victimisation claims and refused deposit order applications. For unfair dismissal, judge found core disputed facts as to whether there was express dismissal or constructive dismissal requiring full hearing. For victimisation, judge found claimant had provided sufficient detail of protected act (complaint in December 2022 referring to discriminatory comments) to meet the high test for strike out of discrimination claims. Applications for £1,000 deposit orders also refused given claimant's limited means and public interest in hearing discrimination claims.

Practical note

Strike out applications for discrimination and unfair dismissal claims will fail where core disputed facts depend on oral evidence, even where documentary evidence appears to support one party's case, and judges must take claimant's case at its highest.

Legal authorities cited

Anyanwu v South Bank Student Union [2001] ICR 391Ahir v British Airways plc [2017] EWCA Civ 1392Mechkarov v City Bank NA [2016] ICR 1121Kaul v Ministry of Justice [2023] UKEATCroke v Leeds City Council UKEAT/0512/07Sivanandan v Independent Police Complaints Commission UKEAT/0436/14Tree v Southeast Coastal Services Ambulance NHS Trust UKEAT/0047/17Hempdan v Ishmael [2017] ICR 486Glasgow City Council v Smith [2015] CSOH 143Willoughby v CF Capital plc [2011] EWCA Civ 1115

Statutes

Employment Tribunal Procedure Rules 2024 rule 40Employment Tribunal Procedure Rules 2024 rule 3ERA 1996 s.95ERA 1996 s.203EqA 2010 s.27Employment Tribunal Procedure Rules 2024 rule 38(1)(a)

Case details

Case number
4106811/2024
Decision date
21 March 2025
Hearing type
preliminary
Hearing days
1
Classification
contested

Respondent

Sector
charity
Represented
Yes
Rep type
solicitor

Claimant representation

Represented
Yes
Rep type
lay rep