Cases1305785/2023

Claimant v Cross Transport Ltd (in administration)

8 January 2025Before Employment Judge BattisbyBirminghamon papers

Outcome

Claimant succeeds

Individual claims

Failure to Inform & Consultsucceeded

The first respondent completely failed to comply with sections 188 and 188A TULR(C)A 1992 requiring collective consultation when proposing to dismiss 20 or more employees as redundant. There was no consultation whatsoever, no trade union or employee representatives, and no steps taken to arrange for election of representatives. The tribunal found this to be a serious breach with no mitigating circumstances.

Facts

Cross Transport Ltd, a road haulage company with 55 employees including 14 claimants, ceased trading on 2 June 2023 and entered administration on 5 June 2023. The company decided on 2 June to make all employees redundant with immediate effect but did not notify them. Administrators wrote to all employees on 8 June 2023 confirming redundancy dismissals. There was no consultation with employees, no recognised trade union, no existing employee representatives, and no steps taken to elect representatives prior to the redundancies.

Decision

The tribunal found the first respondent seriously breached its statutory duty under sections 188 and 188A TULR(C)A 1992 by completely failing to undertake collective consultation before dismissing 20 or more employees as redundant. Following Susie Radin guidance, the tribunal made a protective award of the maximum 90 days for all 14 claimants, finding no mitigating circumstances to justify any reduction despite the cessation of trading.

Practical note

Complete failure to consult when making 20+ employees redundant, even in insolvency situations, will result in maximum 90-day protective awards unless specific mitigating circumstances are demonstrated.

Legal authorities cited

Susie Radin Limited v GMB and others [2004] EWCA Civ 180Independent Insurance Company Ltd v Aspinall and another [2011] IRLR 716

Statutes

TULR(C)A 1992 s.188ATULR(C)A 1992 s.188TULR(C)A 1992 s.190Employment Protection (Recoupment of Jobseeker's Allowance and Income Support) Regulations 1996TULR(C)A 1992 s.189

Case details

Case number
1305785/2023
Decision date
8 January 2025
Hearing type
full merits
Hearing days
Classification
contested

Respondent

Sector
transport
Represented
No

Employment details

Role
Various including lorry drivers

Claimant representation

Represented
No