Cases4106610/2024

Claimant v Astley House Nursing Home Ltd

4 February 2025Before Employment Judge D N JonesScotlandin person

Outcome

Claimant succeeds£27,115

Individual claims

Unfair Dismissalsucceeded

The tribunal found the dismissal was both procedurally and substantively unfair. The respondent failed to investigate properly, did not provide sufficient information for the claimant to respond to allegations, dismissed her through an unauthorised decision-maker who had been note-taker at the investigation, did not consider any sanction other than dismissal, and ignored mitigating factors including the claimant's clean record, length of service, and possible depression. The appeal was a box-ticking exercise with no genuine review.

Wrongful Dismissalsucceeded

The tribunal concluded there was no repudiatory breach of contract justifying summary dismissal. The claimant had clocked in and out honestly, was paid for those hours over two years without challenge, and there was no evidence of dishonesty or intentional disobedience. The respondent produced no disciplinary procedure showing the conduct warranted dismissal without notice.

Unlawful Deduction from Wagessucceeded

The respondent deducted £2,497.95 from the claimant's wages labelled as 'overpayment' but led no evidence about how these sums were calculated, what hours they related to, or whether there was any investigation into authorisation. The claimant had worked all the hours recorded and was entitled to believe that payment for those hours meant they had been authorised by head office. The deductions were therefore unlawful under section 13 ERA 1996.

Facts

The claimant worked as an administrator at a nursing home for over five years. During the pandemic she regularly worked additional hours with approval. From March 2022 she was told to revert to 35 contracted hours with any additional time requiring authorisation from head office, but her manager never monitored this. In June 2024, after a deputy manager queried whether the claimant had authority to attend a vet appointment on work time, the owner investigated and found the claimant had been working and being paid for additional hours over a two-year period. She was dismissed for gross misconduct including alleged fraudulent activity and falsification of timesheets.

Decision

The tribunal found the dismissal was both procedurally and substantively unfair. There was no proper investigation, the claimant was not given sufficient information to respond to allegations, the decision-maker was unauthorised under the respondent's procedures, and no sanction other than dismissal was considered. The claimant was also wrongfully dismissed as there was no repudiatory breach - she had honestly recorded hours worked and was entitled to believe payment meant authorisation. Deductions from wages were unlawful as the respondent provided no evidence of how alleged overpayments were calculated.

Practical note

An employer cannot dismiss for gross misconduct based on working unauthorised overtime when it consistently paid for those hours over two years without challenge, failed to investigate, and dismissed through a fundamentally flawed process that predetermined the outcome.

Award breakdown

Basic award£2,574
Compensatory award£20,462
Notice pay£1,580
Unpaid wages£2,498
Loss of statutory rights£500

Adjustments

Contributory fault15%

The claimant's failure to raise the question of her hours with the respondent was culpable and contributed to dismissal, though at the lower end of the scale as she did not deliberately mislead and had become used to hours being approved. 15% reduction applied to compensatory award only.

ACAS uplift+20%

Significant breaches of ACAS Code including failure to provide enough information to allow claimant to answer allegations and failure to carry out proper investigations. Not a case of small employer with limited resources; group employed over 450 staff and had access to Peninsula HR advice.

Legal authorities cited

Nelson v BBC (No.2) 1980 ICR 110Key Recruitment UK Ltd v Lear [2008] 2 WLUK 585

Statutes

ERA 1996 s.14ERA 1996 s.13ERA 1996 s.123(6)ERA 1996 s.98

Case details

Case number
4106610/2024
Decision date
4 February 2025
Hearing type
full merits
Hearing days
3
Classification
contested

Respondent

Sector
healthcare
Represented
Yes
Rep type
solicitor

Employment details

Role
Administrator
Service
6 years

Claimant representation

Represented
Yes
Rep type
lay rep