Cases6007401/2024

Claimant v Hunslet Ltd

23 January 2025Before Employment Judge BoothNewcastlehybrid

Outcome

Claimant fails

Individual claims

Unfair Dismissalsucceeded

The tribunal found the dismissal unfair because the respondent failed to follow a procedurally fair process. The respondent did not hold a disciplinary hearing and failed to inform the claimant of his right of appeal. Although the reason for dismissal (gross misconduct - speeding at up to 105mph) was potentially fair and the investigation reasonable, the procedural failures meant the dismissal was outside the band of reasonable responses.

Breach of Contractfailed

The tribunal found the claimant's repeated driving at speeds of up to 105mph in excess of lawful speed limits constituted gross misconduct and a fundamental breach of contract. This breach released the respondent from the obligation to give notice or pay in lieu of notice. The wrongful dismissal claim therefore failed.

Facts

The claimant was employed as a driver and provided with a company van. Vehicle tracker data showed he repeatedly drove at speeds significantly in excess of legal limits, including 105mph, during May 2024. When confronted on 30 May 2024, he responded 'I like speed'. He was suspended and invited to a disciplinary hearing but never attended. The respondent dismissed him on 21 June 2024 for gross misconduct without holding a disciplinary hearing or providing a right of appeal. The claimant had over four years' continuous service.

Decision

The tribunal found the dismissal unfair due to procedural failures: no disciplinary hearing was held and no right of appeal provided. However, the tribunal found 100% contributory fault and a 100% Polkey reduction because the claimant's conduct (driving at up to 105mph with no remorse) was gross misconduct and he would inevitably have been fairly dismissed had a proper procedure been followed. The wrongful dismissal claim failed because the gross misconduct was a repudiatory breach releasing the respondent from notice obligations. Total compensation: nil.

Practical note

Even where dismissal is procedurally unfair, a 100% reduction for contributory fault combined with 100% Polkey reduction can result in zero compensation where the misconduct was egregious and dismissal inevitable.

Adjustments

Polkey reduction100%

There is a 100% chance that the claimant would have been fairly dismissed in any event had a proper procedure been followed. If the disciplinary hearing had been rearranged, the respondent would have reached the same decision to dismiss by no later than 28 June 2024.

Contributory fault100%

The claimant drove at speeds far in excess of lawful speed limits (up to 105mph) on multiple occasions. When challenged, he showed no remorse or contrition, responding 'I like speed'. The tribunal found this conduct wholly culpable and blameworthy, posing serious risk to the claimant, others, and the respondent. Both basic and compensatory awards were reduced by 100%.

Legal authorities cited

Sainsbury's Supermarkets Ltd v Hitt [2003] ICR 111BHS v Burchell [1978] IRLR 379Iceland Frozen Foods v Jones [1983] ICR 17Nelson v B.B.C. [1979] WL 69175Langston v Department for Business Enterprise and Regulatory Reform EAT 0534/09Steen v ASP Packaging Ltd [2014] EAT 56X v Y [2004] ICR 1634, CACity and County of Swansea v Gayle [2013] IRLR 768 EATRugby Football Union v Viagogo Ltd [2011] EWCA Civ 1585Laws v London Chronicle (Indicator Newspapers) Ltd [1959] 1 WLR 698, CAPolkey v A E Dayton Services Ltd [1988] ICR 142Foley v Post Office [2000] ICR 1283

Statutes

Human Rights Act 1998 s.3(1)ECHR Article 8Employment Tribunals Extension of Jurisdiction (England and Wales) Order 1994ERA 1996 s.94ERA 1996 s.98ERA 1996 s.122(2)ERA 1996 s.123(6)

Case details

Case number
6007401/2024
Decision date
23 January 2025
Hearing type
full merits
Hearing days
1
Classification
contested

Respondent

Sector
other
Represented
Yes
Rep type
barrister

Employment details

Service
4 years

Claimant representation

Represented
Yes
Rep type
barrister