Cases2312427/2024

Claimant v Headlands Venture Ltd

23 January 2025Before Employment Judge RamsdenLondon Southin person

Outcome

Claimant fails

Individual claims

Automatic Unfair Dismissalfailed

Claimant's own position was that he was dismissed because of his mental health breakdown and the respondent's desire to avoid making reasonable adjustments, not because of any protected disclosures. The tribunal found it not likely that protected disclosures were the reason or principal reason for dismissal.

Unfair Dismissalnot determined

This is an interim relief application only. The substantive unfair dismissal claim was not determined at this hearing and remains to be heard at a full merits hearing.

Direct Discrimination(sexual orientation)not determined

This claim was listed in the claim form but was not addressed in this interim relief hearing. It remains to be determined at the full merits hearing.

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

This claim was listed in the claim form but was not addressed in this interim relief hearing. It remains to be determined at the full merits hearing.

Direct Discrimination(sex)not determined

This claim was listed in the claim form but was not addressed in this interim relief hearing. It remains to be determined at the full merits hearing.

Detrimentnot determined

Protected disclosure detriment claim was listed in the claim form but was not addressed in this interim relief hearing. It remains to be determined at the full merits hearing.

Holiday Paynot determined

This claim was listed in the claim form but was not addressed in this interim relief hearing. It remains to be determined at the full merits hearing.

Unlawful Deduction from Wagesnot determined

This claim was listed in the claim form but was not addressed in this interim relief hearing. It remains to be determined at the full merits hearing.

Facts

The claimant worked as a kitchen porter in a café from May 2022 until around November or December 2024. He left a shift early on 2 November 2024, either quitting or citing mental health concerns. He returned to work on 4 November but did not work thereafter. On 6 December 2024 the respondent sent him his final payslip and advised a P45 would follow. The claimant brought claims including automatic unfair dismissal for whistleblowing and applied for interim relief. The respondent contended the claimant was a casual worker who resigned or abandoned his employment.

Decision

The tribunal dismissed the claimant's application for interim relief. The tribunal found it was not likely the claimant would succeed at final hearing in establishing he made protected disclosures in the public interest, or that any disclosures were the reason for dismissal. The claimant's own case was that he was dismissed because of his mental health breakdown and to avoid making reasonable adjustments, not because of any disclosures.

Practical note

An interim relief application will fail where the claimant's own evidence shows the reason for dismissal was something other than the alleged protected disclosure, even if other elements of the whistleblowing claim may have merit.

Legal authorities cited

Uber BV v Aslam [2021] UKSC 5Carmichael v National Power plc [1999] 4 All ER 879Taplin v C Shippam Ltd [1978] IRLR 450Ministry of Justice v Sarfraz [2011] IRLR 562Dandpat v University of Bath UKEAT/0408/09Simply Smile Manor House Ltd v Ter-Berg [2020] ICR 570Parsons v Airplus UKEAT/0023/16Parkins v Sodexo Ltd [2002] IRLR 109Astle v Travis Perkins PLC ET Case No. 2403488/2020

Statutes

Employment Rights Act 1996 s.47BEmployment Rights Act 1996 s.230Employment Rights Act 1996 s.128Equality Act 2010Employment Rights Act 1996 s.129Employment Rights Act 1996 s.103AEmployment Rights Act 1996 s.43AEmployment Rights Act 1996 s.43BEmployment Rights Act 1996 s.43C

Case details

Case number
2312427/2024
Decision date
23 January 2025
Hearing type
interim
Hearing days
1
Classification
contested

Respondent

Sector
hospitality
Represented
Yes
Rep type
barrister

Employment details

Role
Kitchen Porter
Service
3 years

Claimant representation

Represented
Yes
Rep type
lay rep