Cases3305122/2023

Claimant v Vitalograph Ltd

22 January 2025Before Employment Judge Mr J S BurnsCambridgeremote video

Outcome

Claimant succeeds£10,076

Individual claims

Unfair Dismissalsucceeded

The respondent's defence on liability was struck out under Rule 38 for unreasonable conduct, non-compliance with three tribunal orders regarding witness statement exchange over 13 months, and because it was no longer possible to have a fair hearing. The tribunal entered judgment for the claimant on unfair dismissal. The respondent repeatedly failed to serve witness statements despite directions dated 8/9/23, 20/3/24, and 25/9/24, only serving them one day before the final hearing, fatally prejudicing the claimant's ability to prepare.

Facts

The claimant, a Polish national working remotely in technical support from Northampton, was dismissed in April 2023. The respondent relocated his role to its Ireland premises as part of post-Brexit restructuring. The respondent repeatedly failed to serve witness statements despite three tribunal orders over 13 months (directions dated 8/9/23, 20/3/24, and 25/9/24), only serving them one day before the final hearing on 22/1/25. The claimant, a litigant in person whose first language is not English, argued he was fatally prejudiced in his trial preparation.

Decision

The tribunal struck out the respondent's defence on liability under Rule 38 for unreasonable conduct, non-compliance with orders, and because a fair hearing was no longer possible. Judgment was entered for the claimant on unfair dismissal. Reinstatement/re-engagement was refused as the role no longer existed in the UK. The compensatory award was limited to 16 weeks (£9,776 plus £300 LOSR = £10,076) due to failure to mitigate, as the tribunal found the claimant had not properly sought alternative work despite numerous available IT support roles.

Practical note

Repeated non-compliance with orders for witness statement exchange, especially when prejudicing an unrepresented claimant, can lead to strike-out even where the ultimate sanction is draconian, but tribunals will scrutinise mitigation efforts closely and limit awards where claimants fail to seek available alternative work.

Award breakdown

Compensatory award£10,076
Loss of statutory rights£300

Award equivalent: 17.3 weeks' gross pay

Legal authorities cited

Bolch v Chipman [2004] IRLR 140Blockbuster Entertainment Ltd v James [2006] IRLR 630

Statutes

Employment Protection (Recoupment of Benefits) Regulations 1996Employment Tribunal Rules 2024 Rule 38

Case details

Case number
3305122/2023
Decision date
22 January 2025
Hearing type
full merits
Hearing days
1
Classification
contested

Respondent

Sector
healthcare
Represented
Yes
Rep type
barrister

Employment details

Role
Technical Support (remote)
Salary band
£30,000–£40,000

Claimant representation

Represented
No