Cases3303484/2024

Claimant v Carbon Rewind Ltd

3 February 2025Before Employment Judge YoungWatfordremote video

Outcome

Claimant fails

Individual claims

Automatic Unfair Dismissalfailed

The tribunal found that although the claimant made one protected disclosure (witnessing a customer lock a vulnerable child in a car with a dog), the claimant failed to prove that this was the principal reason for his dismissal. The employer had previously responded supportively to earlier concerns by providing training and assistance. The tribunal concluded the dismissal was for capability reasons, not the protected disclosure, and the claimant could provide no reason why the employer would be motivated to dismiss him for that particular disclosure.

Facts

The claimant worked as a surveyor for one month. He raised concerns about workload, working excessive hours beyond his 40-hour contract, and safety issues including being bitten by a dog and witnessing a customer lock a child in a car with a dog. He sent a detailed email on 14 March 2024 outlining these concerns. The following day, the managing director dismissed him by phone, stating his last day would be 19 March 2024, with the dismissal confirmed by letter citing capability reasons. The claimant appealed, arguing this was whistleblowing retaliation, but the appeal was unsuccessful.

Decision

The tribunal found that only one disclosure qualified as protected (witnessing the child locked in car with dog) but the claimant failed to prove this was the principal reason for dismissal. Most of the alleged disclosures were either too vague, expressed personal concerns rather than public interest matters, or the claimant lacked reasonable belief at the time. The employer had previously responded supportively to earlier concerns by providing training. The claim of automatic unfair dismissal failed.

Practical note

A whistleblowing claim requires more than raising workplace concerns—the claimant must prove the protected disclosure was the principal reason for dismissal, and supportive employer responses to earlier concerns will undermine a claim of retaliatory dismissal based on proximity in time alone.

Legal authorities cited

Cavendish Munro Professional Risks Management Ltd v Geduld [2010] ICR 325Norbrook Laboratories (GB) Ltd v Shaw [2014] ICR 540Eiger Securities LLP v Korshunova [2017] IRLR 115Kraus v Penna Plc [2004] IRLR 260Kilraine v London Borough of Wandsworth [2018] ICR 1850Blackbay Ventures Ltd v Gahir [2014] IRLR 416Kong v Gulf International Bank UK Ltd [2022] IRLR 854Korashi v Abertawe Bro Morgannwg University Local Health Board [2012] IRLR 4Parsons v Airplus International Ltd [2017] UKEAT/0111/17Babula v Waltham Forest College [2007] ICR 1026Millbank Financial Services Ltd v Crawford [2014] IRLR 18Williams v Michelle Brown AM [2019] UKEAT/0044/19

Statutes

ERA 1996 s.43BERA 1996 s.43CERA 1996 s.43AERA 1996 s.103A

Case details

Case number
3303484/2024
Decision date
3 February 2025
Hearing type
full merits
Hearing days
1
Classification
contested

Respondent

Sector
energy
Represented
Yes
Rep type
lay rep

Employment details

Role
surveyor
Service
1 months

Claimant representation

Represented
No