Cases8001244/2024

Claimant v Clydesdale Bank Plc t/a Virgin Money

20 February 2025Before Employment Judge P O'DonnellScotlandin person

Outcome

Claimant fails

Individual claims

Unfair Dismissalfailed

The tribunal found the respondent had a genuine and reasonable belief in the misconduct (altercation with customer, refusing instruction, inappropriate social media post), reached after a reasonable investigation. A fair procedure was followed and dismissal was within the band of reasonable responses. The claimant showed no insight that he had done anything wrong and there was no pre-determined decision to dismiss.

Discrimination Arising from Disability (s.15)(disability)failed

The tribunal assumed (without deciding) that the claimant was disabled and that his conduct arose from ADHD. However, the claim failed because the dismissal was objectively justified: the respondent had a legitimate aim (avoiding repeat aggressive behaviour to customers and staff) and dismissal was a proportionate means of achieving it. The claimant showed no insight or remorse, so a lesser sanction would not have achieved the aim, and no alternative non-customer-facing role was available.

Facts

The claimant was a customer consultant at Virgin Money's Paisley branch. In December 2023, three allegations arose: (1) he had an aggressive altercation with a customer who asked him to quieten down, witnessed by two colleagues who considered pressing the panic button; (2) he refused a manager's instruction to work at the front of the branch, claiming it was too cold; (3) he posted on social media calling his workplace 'toxic as fuck' using the respondent's branding hashtag. He was dismissed after a disciplinary process. The claimant believed his behaviour was due to undiagnosed ADHD.

Decision

The tribunal dismissed both claims. The unfair dismissal claim failed because the respondent had a genuine and reasonable belief in the misconduct after a reasonable investigation, followed fair procedure, and dismissal was within the band of reasonable responses. The disability discrimination claim failed on justification: even assuming the claimant was disabled and his conduct arose from disability, dismissal was a proportionate means of achieving the legitimate aim of preventing repeat aggressive behaviour, given the claimant showed no insight or remorse.

Practical note

Lack of insight or remorse for misconduct can support both the fairness of dismissal and objective justification in disability discrimination claims, particularly where the employer's aim is to prevent recurrence of harmful behaviour.

Legal authorities cited

Sainsbury's Supermarkets Ltd v Hitt [2003] ICR 111Pnaiser v NHS England [2016] IRLR 170MacCulloch v ICI [2008] IRLR 846Lockwood v DWP [2013] IRLR 941Bilka-Kaufhaus GmbH v Weber Von Hartz (case 170/84) [1984] IRLR 317Rainey v Greater Glasgow Health Board [1987] IRLR 26Hardys & Hansons plc v Lax [2005] IRLR 726Seldon v Clarkson Wright & Jakes [2012] ICR 716Polkey v A E Dayton Services Ltd [1988] ICR 142BHS v Burchell [1978] IRLR 379

Statutes

EqA 2010 s.39(2)(c)EqA 2010 s.136ERA 1996 s.94ERA 1996 s.98EqA 2010 s.6EqA 2010 s.15

Case details

Case number
8001244/2024
Decision date
20 February 2025
Hearing type
full merits
Hearing days
5
Classification
contested

Respondent

Sector
financial services
Represented
Yes
Rep type
solicitor

Employment details

Role
Customer Consultant

Claimant representation

Represented
No