Cases8000809/2024

Claimant v Valve Components Ltd (In Administration)

14 March 2025Before Employment Judge L DohertyScotlandon papers

Outcome

Claimant succeeds

Individual claims

Failure to Inform & Consultsucceeded

The respondent dismissed more than 20 employees as redundant at one establishment within 90 days. The respondent failed to ensure that employee representatives were elected in accordance with s.188A TULRCA 1992 and failed to consult with them in accordance with s.188. The tribunal found the complaint well founded.

Facts

The respondent company, in administration, dismissed more than 20 employees as redundant from its East Kilbride establishment within a 90-day period. The claimant was one of those employees, dismissed on 15 March 2024. The respondent failed to ensure that employee representatives were properly elected under s.188A TULRCA 1992 and consequently failed to consult with representatives as required by s.188. No response was submitted to the claim, but the administrator consented to proceedings continuing.

Decision

The tribunal issued judgment on the papers under Rule 22, finding the failure to inform and consult claim well founded. The tribunal made a protective award for the maximum 90-day period starting 15 March 2024, ordering the respondent to pay the claimant remuneration for that protected period due to the collective consultation failures.

Practical note

Employers in administration remain liable for protective awards where they fail to comply with collective redundancy consultation obligations, even where administrators consent to proceedings and no defence is filed.

Legal authorities cited

Statutes

TULRCA 1992 s.188TULRCA 1992 s.188A

Case details

Case number
8000809/2024
Decision date
14 March 2025
Hearing type
rule 21
Hearing days
Classification
default

Respondent

Sector
manufacturing
Represented
No

Claimant representation

Represented
No