Cases3201242/2024

Claimant v Specialist Lining Services Limited

21 February 2025Before Employment Judge Grahame AndersonEast London

Outcome

Claimant succeeds£31,954

Individual claims

Automatic Unfair Dismissalsucceeded

The tribunal found that the claimant's automatic unfair dismissal claim was well-founded. This was likely connected to the TUPE transfer and the respondent's failure to inform or consult about the transfer, which can constitute an automatically unfair reason for dismissal.

Failure to Inform & Consultsucceeded

The tribunal found the claim well founded and made a declaration to that effect. The respondents failed to comply with their obligations under TUPE to inform and consult the claimant about the transfer, leading to an award of £7,916.70.

Unfair Dismissalsucceeded

The tribunal found the unfair dismissal complaint well-founded and determined the claimant was unfairly dismissed. However, the tribunal applied a 35% Polkey reduction, finding there was a 35% chance the claimant would have been fairly dismissed in any event.

Facts

The claimant was dismissed in March 2024 in circumstances involving a TUPE transfer between three related companies. The respondents failed to inform or consult the claimant about the TUPE transfer as required by law. The claimant brought claims for automatic unfair dismissal, unfair dismissal, and failure to inform or consult under TUPE, representing himself at a four-day hearing.

Decision

The tribunal found all three claims well-founded. The claimant succeeded in automatic unfair dismissal, unfair dismissal (with a 35% Polkey reduction), and failure to inform/consult under TUPE. The claimant was awarded £24,037.72 for unfair dismissal and £7,916.70 for the TUPE consultation failure, totaling £31,954.42.

Practical note

Employers must strictly comply with TUPE information and consultation obligations; failure to do so can result in both separate compensation awards and support findings of automatic unfair dismissal when a dismissal occurs in the context of a transfer.

Award breakdown

Compensatory award£24,038

Adjustments

Polkey reduction35%

There was a 35% chance that the claimant would have been fairly dismissed in any event

Legal authorities cited

Polkey v A E Dayton Services Ltd [1988] ICR 142

Statutes

TUPE RegulationsERA 1996

Case details

Case number
3201242/2024
Decision date
21 February 2025
Hearing type
full merits
Hearing days
4
Classification
contested

Respondent

Sector
construction
Represented
Yes
Rep type
solicitor

Claimant representation

Represented
No