Cases1801994/2024

Claimant v Khupe Legal Services Limited

15 January 2025Before Employment Judge ThemistocleousLeedsin person

Outcome

Claimant fails

Individual claims

Constructive Dismissalwithdrawn

Claimant accepted at the outset that she was employed by the Second Respondent at the time of resignation, following an intra-group transfer in April 2022. All claims against the First Respondent were withdrawn and dismissed.

Constructive Dismissalfailed

The tribunal found that the meetings on 2 and 9 November 2023 were conducted appropriately as fact-finding exercises. No allegations were inappropriately put to the claimant, no derogatory language was used, and the respondent was justified in questioning the recruitment process involving the claimant's son. The tribunal held that the respondent's conduct was not calculated or likely to destroy or seriously damage the relationship of trust and confidence, therefore there was no repudiatory breach of contract and no constructive dismissal.

Wrongful Dismissalfailed

As the tribunal found the claimant was not constructively dismissed, there could be no dismissal in breach of contract. The wrongful dismissal claim therefore failed as a consequence.

Facts

The claimant was employed as a PA/Executive Assistant and was involved in recruiting for a Recruitment Officer role for which her son applied. The respondent became concerned that proper procedures had not been followed when the son was offered the role without the managing director's approval or knowledge, and without all candidates being interviewed. At a meeting on 2 November 2023, the respondent questioned what had happened, leading the claimant to become upset and go on sick leave. At a return to work meeting on 9 November 2023, the respondent expressed no remorse for how the earlier meeting was conducted, at which point the claimant resigned immediately.

Decision

The tribunal dismissed all claims. It found that the respondent was justified in questioning the recruitment process and that the meetings were appropriate fact-finding exercises. No inappropriate allegations were made, no derogatory language was used, and the presence of other managers was reasonable given their involvement. The respondent's conduct did not breach the implied term of trust and confidence, so there was no constructive dismissal and consequently no wrongful dismissal.

Practical note

Employers can legitimately question potential conflicts of interest or procedural irregularities in recruitment processes involving employees' family members, and fact-finding meetings conducted reasonably will not amount to breaches of trust and confidence even if uncomfortable for the employee.

Legal authorities cited

Western Excavating v Sharp [1978] ICR 221Kaur v Leeds Teaching Hospitals NHS Trust [2018] EWCA Civ 978Lewis v Motorworld Garages Ltd [1986] ICR 157Malik v Bank of Credit and Commerce International [1998] AC 20London Borough of Waltham Forest v Omilaju [2004] EWCA Civ 1493

Statutes

Employment Rights Act 1996 s.95(1)(c)

Case details

Case number
1801994/2024
Decision date
15 January 2025
Hearing type
full merits
Hearing days
2
Classification
contested

Respondent

Sector
legal services
Represented
Yes
Rep type
barrister

Employment details

Role
Personal Assistant / Executive Assistant
Service
3 years

Claimant representation

Represented
Yes
Rep type
barrister