Cases2302983/2024

Claimant v Proterms Limited

26 February 2025Before Employment Judge L WilsonLondon Southremote video

Outcome

Claimant succeeds

Individual claims

Wrongful Dismissalsucceeded

The tribunal found that whilst there were some functional issues with the website the claimant developed, these did not amount to gross negligence or a repudiatory breach of contract. The claimant's conduct did not disclose a deliberate intention to disregard essential contractual requirements. The tribunal concluded the dereliction of duty was not so grave and weighty as to justify summary dismissal, particularly as many issues had been resolved by the time of dismissal.

Facts

The claimant was employed as a Tech Lead/full stack developer from September 2023 to develop a new website for the respondent. He was summarily dismissed on 14 February 2024 for alleged poor performance. The respondent claimed he was negligent, lacked qualifications, and worked for third parties. Following the website launch on 8 January 2024, various functional issues arose including payment processing problems, slow loading speeds, a website crash, and failure to implement cookie consent. The respondent also brought a counterclaim for losses arising from the claimant's alleged negligence.

Decision

The tribunal found the wrongful dismissal claim succeeded. While some functional issues arose post-launch, these did not amount to gross negligence or repudiatory breach. The claimant had demonstrated sufficient skill and capability throughout most of his employment, including during the development phase. The tribunal found reasonable explanations for many issues and concluded the claimant's conduct did not disclose deliberate disregard of essential contractual requirements. The respondent's counterclaim was dismissed. A remedy hearing was ordered.

Practical note

Not all performance issues, even collectively, will amount to gross negligence justifying summary dismissal; tribunals will scrutinize whether the employer's trust had actually been destroyed to the requisite degree contemporaneously, not retrospectively.

Legal authorities cited

Laws v London Chronicle (Indicator Newspapers) Ltd [1959] 1 WLR 698Briscoe v Lubrizol Ltd [2002] IRLR 607Neary and anor v Dean of Westminster [1999] IRLR 288Dietmann v Brent London Borough Council [1988] ICR 842Robert Bates Wrekin Landscapes Ltd v Knight EAT 0164/13Kempster v Cantor Fitzgerald (UK) Ltd unreported 19.1.95Adesokan v Sainsbury's Supermarkets Ltd [2017] ICR 590Boston Deep Sea Fishing and Ice Co v Ansell (1888) 39 ChD 339Enable Care and Home Support Ltd v Pearson EAT 0366/09McFarlane v Relate Avon Ltd [2010] ICR 507A v B [2010] ICR 849Leach v Office of Communications [2012] ICR 1269

Case details

Case number
2302983/2024
Decision date
26 February 2025
Hearing type
full merits
Hearing days
1
Classification
contested

Respondent

Sector
legal services
Represented
Yes
Rep type
barrister

Employment details

Role
Tech Lead
Service
5 months

Claimant representation

Represented
No