Cases6004074/2025

Claimant v Manchester University NHS Foundation Trust

28 February 2025Before Employment Judge JohnsonLiverpoolremote video

Outcome

Claimant fails

Individual claims

Automatic Unfair Dismissalfailed

The tribunal was not satisfied there was a 'pretty good chance of success' for interim relief purposes. The documentary evidence supported the respondent's contention that the claimant was employed on a fixed-term contract covering maternity leave which ended on 31 January 2025 as contractually agreed. While protected disclosures may have been made, the tribunal was not persuaded on the limited evidence that whistleblowing was the principal reason for dismissal rather than the ending of the fixed-term contract.

Direct Discrimination(race)not determined

Claim mentioned in the ET1 but not determined at this interim relief hearing, which concerned only the automatic unfair dismissal/whistleblowing claim.

Discrimination Arising from Disability (s.15)(disability)not determined

Claim mentioned in the ET1 but not determined at this interim relief hearing. The claimant has Multiple Sclerosis and takes 10 different medications.

Breach of Contractnot determined

Claim mentioned in the ET1 but not determined at this interim relief hearing.

Holiday Paynot determined

Claim mentioned in the ET1 but not determined at this interim relief hearing.

Unlawful Deduction from Wagesnot determined

Claim mentioned in the ET1 but not determined at this interim relief hearing.

Facts

Dr Abdulwhab was employed as a Senior LED in Asthma Research on a fixed-term contract from 5 August 2024 to 31 January 2025 as maternity cover. He alleged he made protected disclosures about failures in vetting when recruiting staff. The respondent ended his contract on the agreed date as the person on maternity leave was returning and there was only funding for one doctor in the post. Access to email, WhatsApp groups and building card access was removed in the final weeks of employment. The claimant brought claims including automatic unfair dismissal for whistleblowing, race and disability discrimination, and various pay claims.

Decision

The tribunal refused the application for interim relief. The documentary evidence supported that the claimant was employed on a genuine fixed-term contract ending on 31 January 2025. The tribunal was not satisfied there was a 'pretty good chance' that whistleblowing was the principal reason for dismissal rather than the lawful expiry of the fixed-term contract. The claim may be arguable at a full merits hearing but did not meet the high threshold required for interim relief.

Practical note

Applications for interim relief in whistleblowing dismissals face a high threshold and will fail where clear contractual documentation supports an alternative explanation for dismissal, such as the genuine expiry of a fixed-term contract.

Legal authorities cited

Cavendish Munro Professional Risks Management Ltd v Geduld [2010] ICR 325Taplin v C.Shippam Limited [1978] ICR 1068Ministry of Justice v Sarfaz [2011] ICR 562Al Qasimi v Robinson EAT 0283/17Hancock v Ter-Berg & anor UKEAT/0138/19/BARoyal Mail Ltd v Jhuti [2020] 3 All E.R. 257Kilraine v London Borough of Wandsworth [2018] ICR 1850Blackbay Venture Limited v Gahir [2014] ICR 747Chesterton Global Ltd v Nurmohamed [2018] ICR 731

Statutes

ERA 1996 s.130ERA 1996 Part IVAERA 1996 s.43BERA 1996 s.103AERA 1996 s.128ERA 1996 s.129

Case details

Case number
6004074/2025
Decision date
28 February 2025
Hearing type
interim
Hearing days
1
Classification
contested

Respondent

Sector
healthcare
Represented
Yes
Rep type
barrister

Employment details

Role
Senior LED in Asthma Research
Service
6 months

Claimant representation

Represented
No