Cases2402883/2024

Claimant v Sustainable Energy First Limited

30 January 2025Before Employment Judge Phil AllenManchesterremote video

Outcome

Partly successful

Individual claims

Unfair Dismissalstruck out

The ordinary unfair dismissal claim under section 94 ERA 1996 was struck out as having no reasonable prospect of success, likely due to insufficient qualifying service or another jurisdictional bar.

Automatic Unfair Dismissalpartly succeeded

The automatic unfair dismissal claim under section 103A ERA 1996 based on the alleged protected disclosure on 21 March 2024 at 2:06pm was struck out as having no reasonable prospect of success, but the claim based on the alleged protected disclosure on 15 March 2024 was allowed to proceed.

Whistleblowingpartly succeeded

The whistleblowing detriment claim based on the alleged protected disclosure on 21 March 2024 at 2:06pm was struck out as having no reasonable prospect of success, but the claim based on the alleged protected disclosure on 15 March 2024 was allowed to proceed.

Victimisationpartly succeeded

The victimisation complaint based on the alleged protected act on 21 March 2024 at 2:06pm was struck out as having no reasonable prospect of success, but the victimisation complaint based on the alleged protected act on 15 March 2024 was allowed to proceed.

Facts

The claimant brought claims including ordinary unfair dismissal, automatic unfair dismissal for whistleblowing, and victimisation. The respondent applied to strike out various claims. The claims relied on alleged protected disclosures and protected acts made on 15 March 2024 and 21 March 2024 at 2:06pm.

Decision

The tribunal struck out the ordinary unfair dismissal claim and the claims based on alleged protected acts/disclosures made on 21 March 2024 at 2:06pm as having no reasonable prospect of success. However, claims based on events of 15 March 2024 were allowed to proceed to a full hearing.

Practical note

Tribunals will scrutinize the timing and nature of alleged protected disclosures and protected acts, striking out claims based on specific communications that lack reasonable prospects while allowing other aspects of the case to proceed.

Legal authorities cited

Statutes

ERA 1996 s.94ERA 1996 s.103A

Case details

Case number
2402883/2024
Decision date
30 January 2025
Hearing type
strike out
Hearing days
1
Classification
procedural

Respondent

Sector
energy
Represented
Yes
Rep type
barrister

Claimant representation

Represented
No