Cases2406111/2023

Claimant v One Fylde

14 March 2025Before Employment Judge DennehyManchesterremote video

Outcome

Partly successful£6,105

Individual claims

Unfair Dismissalsucceeded

The tribunal found the claimant was procedurally unfairly dismissed. The respondent failed to conduct a thorough investigation, specifically failing to re-interview the co-worker who made the complaint when the claimant suggested a motive for that complaint. This unfairness was not corrected at the disciplinary or appeal stage.

Facts

The claimant was a care worker employed by One Fylde to care for vulnerable adults. On 19 September 2022, the claimant admitted spraying deodorant on a clean incontinence pad of a vulnerable service user and saying the service user looked pregnant. A co-worker made a complaint about this conduct. The claimant was suspended, disciplined and dismissed for gross misconduct. The claimant argued the co-worker had a malicious motive for the complaint and cited unreported concerns about that co-worker. The respondent failed to re-interview the co-worker to explore the claimant's explanation for motive.

Decision

The tribunal found the dismissal was procedurally unfair due to the respondent's failure to conduct a thorough investigation. However, the claimant's basic award was reduced by 50% for contributory fault due to her admitted misconduct, failure to report concerns, lack of insight, and denial of wrongdoing. The compensatory award was reduced by 75% under Polkey principles because the tribunal found a 75% chance the claimant would have been dismissed anyway had a fair process been followed, given the seriousness of her admitted conduct. The total award was £6,105.11.

Practical note

Even where an employer's investigation is procedurally deficient, substantial Polkey and contributory fault reductions can apply where the employee's admitted conduct alone constitutes serious misconduct justifying dismissal, particularly in care settings involving vulnerable adults.

Award breakdown

Basic award£3,305
Compensatory award£2,800

Adjustments

Polkey reduction75%

75% chance that the claimant would still have been dismissed had the respondent conducted a fair investigation and the dismissal would have been within the range of reasonable responses, due to the seriousness of the claimant's admitted misconduct against a vulnerable adult

Contributory fault50%

Claimant sprayed deodorant on clean incontinence pad of vulnerable service user and said service user looked pregnant; failed to report concerns about co-worker misconduct; lacked insight into how her admitted conduct affected the service user and co-workers; consistently denied wrongdoing despite breaching code of conduct

Legal authorities cited

Hill v Governing Body of Great Tey Primary School [2013] IRLR 274Steen v ASP Packaging [2014] ICR 56Polkey v A E Dayton Services Ltd [1988] ICR 142

Statutes

Employment Rights Act 1996 s.123(6)Employment Rights Act 1996 s.122(2)

Case details

Case number
2406111/2023
Decision date
14 March 2025
Hearing type
remedy
Hearing days
3
Classification
contested

Respondent

Sector
healthcare
Represented
Yes
Rep type
barrister

Employment details

Claimant representation

Represented
Yes
Rep type
barrister