Cases1401065/2024

Claimant v Serenity Nails and Beauty Limited

17 January 2025Before Employment Judge HogarthSouthamptonremote video

Outcome

Claimant succeeds

Individual claims

Unlawful Deduction from Wagessucceeded

The tribunal found that the second respondent made an unauthorised deduction of £500 from the claimant's wages for November 2023, which was unlawful under the Employment Rights Act 1996.

Unfair Dismissalsucceeded

The tribunal found the claimant was unfairly dismissed by the second respondent. The respondent unreasonably failed to follow the ACAS Code on disciplinary procedures, but the dismissal was subject to a Polkey reduction of 60% after 20 December 2023 and contributory fault of 25%.

Facts

The claimant was employed by the second respondent and had claims against both respondents. Claims against the first respondent were withdrawn. The second respondent deducted £500 from the claimant's November 2023 wages without authorisation and dismissed the claimant unfairly. The respondent failed to follow proper ACAS disciplinary procedures, though there was evidence of contributory conduct by the claimant.

Decision

The tribunal upheld the claims for unlawful deduction of wages (£500) and unfair dismissal against the second respondent. The unfair dismissal award will be subject to multiple adjustments: a 60% Polkey reduction for losses after 20 December 2023, 25% contributory fault reduction, and a 17.5% ACAS uplift. A remedy hearing was ordered to calculate the final awards.

Practical note

Even where an employer has substantive grounds for dismissal and the employee contributed to their own dismissal, failure to follow ACAS procedures can still result in a finding of unfair dismissal with a modest uplift, though significant Polkey and contributory fault reductions may substantially limit the final award.

Adjustments

Polkey reduction60%

60% Polkey reduction applied to any compensatory award in respect of losses after 20 December 2023

Contributory fault25%

Basic award reduced by 25% for contributory conduct under s.122(2) ERA 1996; compensatory award reduced by 25% for contributory conduct under s.123(6) ERA 1996

ACAS uplift+17.5%

Compensatory award increased by 17.5% for unreasonable failure to follow the ACAS Code of Practice on Disciplinary and Grievance Procedures under s.207A TULRCA 1992

Legal authorities cited

Polkey v A E Dayton Services Ltd [1988] ICR 142

Statutes

ERA 1996 s.123(6)TULRCA 1992 s.207AERA 1996 s.122(2)

Case details

Case number
1401065/2024
Decision date
17 January 2025
Hearing type
full merits
Hearing days
2
Classification
contested

Respondent

Sector
hospitality
Represented
Yes
Rep type
lay rep

Claimant representation

Represented
Yes
Rep type
lay rep