Cases2501766/2024

Claimant v Alicia Coffee House Limited

25 January 2025Before Employment Judge MorrisNewcastleremote video

Outcome

Claimant fails

Individual claims

Constructive Dismissalfailed

The tribunal found that the respondent did not breach the claimant's contract of employment, either through failure to pay full salary or by removing her managerial duties. The evidence showed the claimant continued to perform her key managerial tasks after the TUPE transfer. The conduct relied upon did not amount to a fundamental breach of the implied term of trust and confidence. The claimant failed to discharge the burden of proving that the respondent's conduct destroyed or seriously damaged the relationship of trust and confidence without reasonable and proper cause.

Facts

The claimant was manager of a coffee shop whose employment transferred to the respondent under TUPE on 4 March 2024. She claimed that after the transfer her managerial role was eroded, her salary was reduced, and the supervisor was given a higher hourly rate and her duties. She resigned on 11 June 2024 citing the job role no longer being available, and relying on a 'last straw' incident where her manager allegedly mocked her over an incorrectly completed disciplinary process. The respondent denied the allegations and argued the claimant continued to perform her full managerial role and was paid her contractual salary in full.

Decision

The tribunal found the claimant had not established a breach of contract. The evidence showed she continued to perform her key managerial duties including rotas, staff holidays, ordering, banking, and disciplinary matters. Her salary was paid in full and she had agreed to the change from annual to hourly basis. The 'last straw' incident on 11 June 2024 did not constitute a breach and was not mentioned in her resignation letter. There was no dismissal, so the unfair dismissal claim was dismissed.

Practical note

A claimant alleging constructive dismissal following a TUPE transfer must provide clear documentary evidence that managerial duties were removed; self-serving oral evidence contradicted by contemporaneous documents and witness questionnaires will not suffice to establish a fundamental breach.

Legal authorities cited

Western Excavating v Sharp [1978] ICR 221Woods v WM Car Services (Peterborough) Limited [1981] IRLR 347Gogay v Hertfordshire County Council [2000] IRLR 703Lewis v Motorworld Garages Limited [1985] IRLR 465Omilaju v Waltham Forest London Borough Council [2005] ICR 481Kaur v Leeds Teaching Hospitals NHS Trust [2018] EWCA Civ 978Cantor Fitzgerald International v Callaghan [1999] ICR 639R F Hill Ltd v Mooney [1981] IRLR 258Morrow v Safeway Stores plc [2002] IRLR 9Malik v Bank of Credit and Commerce International [1998] AC 20

Statutes

Employment Rights Act 1996 s.94Employment Rights Act 1996 s.95(1)(c)Employment Rights Act 1996 s.98Employment Rights Act 1996 s.111Transfer of Undertakings (Protection of Employment) Regulations 1981

Case details

Case number
2501766/2024
Decision date
25 January 2025
Hearing type
full merits
Hearing days
2
Classification
contested

Respondent

Sector
hospitality
Represented
Yes
Rep type
lay rep

Employment details

Role
Manager of Sunderland coffee shop
Salary band
£25,000–£30,000
Service
5 years

Claimant representation

Represented
No