Cases2406768/2024

Claimant v Taylor Davenport Resourcing Limited

Outcome

Claimant fails

Individual claims

Unfair Dismissalnot determined

Interim relief application only. Full merits hearing yet to take place.

Automatic Unfair Dismissalfailed

The tribunal was not persuaded the claimant made protected disclosures as alleged. The claimant claimed 18 oral disclosures over 18 months but provided no contemporaneous written evidence. The tribunal found the claimant's narrative unconvincing, particularly her return to an allegedly harassing employer and the belated escalation only when facing redundancy. The tribunal also found the respondent's explanation that commission was mistakenly entered as expenses credible, and noted the claimant never raised concerns with the shared accountancy firm. The tribunal concluded the claimant did not have a 'pretty good chance' of establishing the dismissal was for whistleblowing.

Whistleblowingfailed

The tribunal rejected the interim relief application, finding the claimant unlikely to establish she made qualifying protected disclosures. The alleged disclosures were oral, lacked contemporaneous corroboration, and were only raised in writing after redundancy consultation began. The tribunal found the respondent's account that payroll errors were corrected immediately upon discovery more credible than the claimant's allegation of deliberate tax evasion.

Discrimination Arising from Disability (s.15)(disability)not determined

Full merits hearing yet to take place. Interim relief not available for disability discrimination claims.

Direct Discrimination(disability)not determined

Full merits hearing yet to take place. Interim relief not available for discrimination claims.

Harassment(disability)not determined

Full merits hearing yet to take place. The tribunal noted harassment and direct discrimination are mutually exclusive claims.

Failure to Make Reasonable Adjustments(disability)not determined

Full merits hearing yet to take place. Interim relief not available for reasonable adjustments claims.

Facts

The claimant worked as Director of Recruitment for a public sector recruitment agency from July 2020 to September 2024. She claimed she made 18 protected disclosures between January 2023 and September 2024 alleging the respondent fraudulently processed her commission as expenses to reduce tax. The respondent denied this, stating commission was entered incorrectly by administrative error, which was corrected and tax paid when discovered. The claimant was made redundant in September 2024 due to lack of new clients and placements in her region since 2022. She applied for interim relief claiming automatic unfair dismissal for whistleblowing.

Decision

The tribunal refused the interim relief application. The judge was not persuaded the claimant made protected disclosures, noting all but one were allegedly oral with no contemporaneous corroboration, the claimant never raised concerns with their shared accountant, and only raised a written grievance after being notified of redundancy. The tribunal found the respondent's explanation of administrative error credible and the claimant's narrative unconvincing, falling well below the 'pretty good chance of success' threshold required for interim relief.

Practical note

Interim relief applications in whistleblowing cases require strong contemporaneous evidence of protected disclosures; purely oral allegations made over many months without written corroboration or escalation, raised only when facing redundancy, will not meet the high threshold of a 'pretty good chance of success'.

Legal authorities cited

Cavendish Munro Professional Risks Management Ltd v Geduld [2010] ICR 325London City Airport Ltd v Chacko [2013] IRLR 610Taplin v C Shippam Ltd [1978] ICR 1068Ministry of Justice v Sarfraz [2011] IRLR 562Al Qasimi v Robinson EAT 0283/17Steer v Stormsure Ltd [2021] ICR 807Chesterton Global Limited & Verman v Nurmohamed & Public Concern At Work [2017] EWCA Civ 979Kilraine v London Borough of Wandsworth [2018] ICR 1850Babula v Waltham Forest College [2007] ICR 1026

Statutes

ERA 1996 s129ERA 1996 ss43A-43HERA 1996 s43BERA 1996 s43CEqA 2010 s13EqA 2010 s21EqA 2010 s15EqA 2010 s26Enterprise and Regulatory Reform Act 2013 s17ERA 1996 s94

Case details

Case number
2406768/2024
Decision date
24 January 2025
Hearing type
interim relief
Hearing days
1
Classification
contested

Respondent

Sector
professional services
Represented
No

Employment details

Role
Director of Recruitment
Service
4 years

Claimant representation

Represented
No