Cases2304618/2020

Claimant v Virgin Atlantic Airways Limited

10 January 2025Before Employment Judge D WrightLondon Southhybrid

Outcome

Partly successful

Individual claims

Unfair Dismissalpartly succeeded

The tribunal found dismissals of senior cabin crew (MS claimants, Paula Lin, TC12, Lyndsey Stevenson) were procedurally unfair due to the complexity of the computer-based selection programme (calculations to 15 decimal places), inadequate time for crew to understand their data, and no provisional selection stage ('you have been selected for redundancy' on 11/6/2020 was final). However, need for redundancies was justified and selection criteria agreed with Unite were fair.

Direct Discrimination(age)failed

The tribunal found VAA had not unlawfully selected older cabin crew or protected younger cabin crew. No evidence that age played any part in the redundancy process; VAA acted in difficult circumstances without ulterior motive.

Indirect Discrimination(age)failed

Tribunal found no indirect age discrimination. The selection criteria and process, though complex and procedurally flawed, was not designed to disadvantage older employees and most aspects were agreed with Unite.

Direct Discrimination(sex)withdrawn

MS claimants withdrew all direct sex discrimination claims (issues 41.4, 45, 46, 47, 56, 57, 58) on 11/7/2024.

Indirect Discrimination(sex)withdrawn

MS claimants withdrew all indirect sex discrimination claims on 11/7/2024.

Detrimentfailed

Claims of detriment contrary to s.43C ERA (related to statutory leave) failed and were dismissed.

Otherfailed

Claims under Part-Time Worker (Prevention of Less Favourable Treatment) Regulations 2000 failed and were dismissed. No less favourable treatment due to part-time working was established.

Facts

Virgin Atlantic Airways faced severe financial pressure during the Covid-19 pandemic and announced large-scale redundancies on 5/5/2020 affecting approximately 1,692 cabin crew across two phases. Selection criteria (on-board performance, conduct, absence, punctuality, loyalty) were agreed with Unite the Union following collective consultation on 19/5/2020. Over 400 claims were presented by cabin crew who were made redundant, with 12 test cases selected for hearing. VAA used a complex computer programme based on Voice of Customer data, performance monitoring, and other criteria, with calculations running to 15 decimal places which proved difficult for crew to understand and replicate.

Decision

The tribunal found that while the need for redundancies was justified and the selection criteria agreed with Unite were fair, the dismissals of senior cabin crew (MS claimants and some others) were procedurally unfair due to: the excessive complexity of the scoring system; inadequate time for crew to understand their data; and the absence of provisional selection (crew were told definitively 'you have been selected for redundancy' on 11/6/2020). However, all discrimination claims failed as the tribunal found no evidence that age or sex influenced the process, and VAA had no ulterior motive.

Practical note

Even when redundancy selection criteria are fair and agreed with unions, excessive complexity in scoring methodology (e.g. calculations to 15 decimal places) and failure to provide intelligible data to employees in sufficient time before making final selection decisions can render dismissals procedurally unfair, despite the employer acting without malicious intent in a crisis.

Legal authorities cited

Statutes

EqA 2010 s.123ERA 1996 s.98Part-Time Workers (Prevention of Less Favourable Treatment) Regulations 2000TULRCA 1992 s.188ERA 1996 s.111EqA 2010 s.13EqA 2010 s.19

Case details

Case number
2304618/2020
Decision date
10 January 2025
Hearing type
full merits
Hearing days
30
Classification
contested

Respondent

Sector
transport
Represented
Yes
Rep type
barrister

Employment details

Role
Cabin Crew

Claimant representation

Represented
Yes
Rep type
multiple