Cases6005079/2024

Claimant v Rotable Repairs Limited

15 January 2025Before Employment Judge GardinerLondon Eastremote video

Outcome

Partly successful

Individual claims

Unfair Dismissalpartly succeeded

The claim succeeded on procedural grounds because the Claimant should have been provided with the outcome of Mr French's conversation with the testing facility and his internet research. However, the tribunal found the Claimant would have been fairly dismissed in any event due to genuine belief in misconduct following reasonable investigation, making dismissal within the band of reasonable responses.

Facts

The Claimant was dismissed following a positive drug test for cocaine. The dismissal was found to be procedurally unfair because the Claimant was not shown the outcome of Mr French's conversation with the testing facility or his internet research before the disciplinary hearing. However, the Respondent had a Drug & Alcohol Policy with zero tolerance for drug usage, and evidence showed similar cases resulted in dismissal unless employees self-referred. The Claimant did not self-refer.

Decision

This is a reconsideration judgment refusing the Claimant's second application to reconsider. The tribunal found no reasonable prospect of varying the original decision. Although the unfair dismissal claim succeeded on narrow procedural grounds, the Claimant would have been fairly dismissed in any event (100% Polkey reduction), making reinstatement unjust and equitable. New arguments raised only at reconsideration stage were rejected.

Practical note

A procedural unfair dismissal finding does not guarantee remedy where a 100% Polkey reduction applies and the employee's own gross misconduct wholly caused the dismissal, making reinstatement inappropriate under s.116 ERA 1996.

Adjustments

Polkey reduction100%

The Claimant would certainly have been fairly dismissed in any event even if the procedural failing had not occurred

Legal authorities cited

Statutes

ERA 1996 s.116

Case details

Case number
6005079/2024
Decision date
15 January 2025
Hearing type
reconsideration
Hearing days
1
Classification
procedural

Respondent

Sector
manufacturing
Represented
Yes
Rep type
barrister

Claimant representation

Represented
No