Cases2404435/2023

Claimant v Kidzrus Nursery Limited

16 January 2025Before Employment Judge Phil AllenManchesterin person

Outcome

Claimant succeeds£1,537

Individual claims

Unfair Dismissalsucceeded

The tribunal found the dismissal was unfair because dismissing the claimant for being absent without leave on a single occasion and not being contactable on that day was not within the range of reasonable responses which a reasonable employer would make. The respondent failed to carry out a reasonable investigation and insisted on conducting the disciplinary process while the claimant was certified as not fit to attend work due to stress.

Facts

Ms Lindley was a part-time term-time childcare practitioner employed from March 2016 to December 2022. She had been taking a 10-minute break for three years, which was stopped in June 2022. She later requested the break be reinstated due to mental health concerns, which was refused. On 21 October 2022, she failed to attend work due to a childcare emergency (school closure) after her leave request was not formally approved. She was subsequently signed off work due to stress. The respondent conducted a disciplinary process entirely during her sick leave absence and summarily dismissed her on 9 December 2022, shortly after she had resigned giving four weeks' notice.

Decision

The tribunal found the dismissal was unfair. Dismissing the claimant for a single absence without leave was not within the range of reasonable responses a reasonable employer would make. The respondent failed to conduct a reasonable investigation and insisted on completing the entire disciplinary process while the claimant was certified as unfit for work due to stress. The tribunal reduced the awards by 20% for contributory fault (the claimant's decision not to attend work despite not having formal approval) and increased the compensatory award by 10% for the respondent's unreasonable failure to comply with the ACAS Code.

Practical note

An employer cannot fairly dismiss an employee for a single day's unauthorised absence, particularly where the dismissal process is conducted entirely while the employee is certified as unfit for work due to stress at work, and where the investigation failed to meet basic standards of reasonableness.

Award breakdown

Basic award£1,254
Compensatory award£283

Adjustments

Contributory fault20%

Claimant decided not to attend work on 21 October 2022 despite knowing she was required to do so and did not return her manager's telephone call that day. However, the tribunal noted she had told her manager in advance she would be absent due to unavoidable childcare issues.

ACAS uplift+10%

Respondent unreasonably failed to comply with ACAS Code by not carrying out necessary investigations as required and conducting the entire disciplinary process while the claimant was certified as not fit for work due to stress at work.

Legal authorities cited

BHS v Burchell [1978] IRLR 379A v B [2003] IRLR 405Mbubaegbu v Homerton University Hospital NHS Foundation Trust UKEAT/0218/17Nelson v BBC (No 2) [1979] IRLR 346Andrews v Software 2000 Limited [2007] ICR 825Wolff v Kingston upon Hull City Council UKEAT/0631/06Swallow Security Services v Millicent EAT 0297/08Sainsbury's Supermarkets Ltd v Hitt [2003] ICR 111Polkey v A E Dayton Services Ltd [1988] ICR 142

Statutes

ERA 1996 s.123ERA 1996 s.123(6)ERA 1996 s.88(1)(b)TULRCA 1992 s.207AERA 1996 s.94ERA 1996 s.98ERA 1996 s.98(4)ERA 1996 s.119ERA 1996 s.122(2)

Case details

Case number
2404435/2023
Decision date
16 January 2025
Hearing type
full merits
Hearing days
2
Classification
contested

Respondent

Sector
education
Represented
Yes
Rep type
in house

Employment details

Role
part-time, term-time, level three childcare practitioner
Service
7 years

Claimant representation

Represented
Yes
Rep type
barrister