Cases1602469/2024

Claimant v Life Sciences Hub Wales Limited

11 December 2024Before Employment Judge S PoveyCardiffhybrid

Outcome

Claimant succeeds

Individual claims

Unfair Dismissalsucceeded

The tribunal found the dismissal unfair due to multiple procedural failures: (1) The respondent placed the claimant in a pool of one without considering whether other employees should be included and without consulting on pooling in advance; (2) The respondent failed to apply its mind to voluntary redundancy despite its own policy allowing it, particularly when another employee (Ms Virgill) was seeking to exit; (3) The respondent failed to consider 'bumping' Ms Virgill's role to the claimant; (4) The respondent failed to pause external recruitment during consultation or offer vacant roles at the end of the process. These cumulative failures meant the dismissal fell outside the range of reasonable responses.

Facts

The claimant was employed as a Finance & Accounts Assistant from December 2019. In February 2024, while on sick leave, she was told her role was at risk due to budget constraints. She was placed in a pool of one. The respondent held four consultation meetings and offered her six vacant posts in February/March 2024, which she did not apply for as she wanted to save her existing job. She was dismissed for redundancy on 2 May 2024. Another employee, Ms Virgill, was seeking voluntary redundancy at the same time but was told it was not available. Ms Virgill's post remained unfilled from April 2024 until she left in August 2024.

Decision

The tribunal found there was a genuine redundancy situation but the dismissal was unfair due to multiple procedural failures. The respondent failed to consult before deciding on a pool of one, failed to consider whether other employees should be in the pool, failed to apply its mind to voluntary redundancy or bumping Ms Virgill's role to the claimant, and failed to pause external recruitment. No Polkey or contributory conduct reductions were appropriate. The case was listed for a remedy hearing.

Practical note

When selecting a pool of one for redundancy, employers must consult before making that decision and actively consider wider pooling, voluntary redundancy, bumping, and pausing external recruitment — failing to explore these options can render the dismissal unfair even where a genuine redundancy situation exists.

Legal authorities cited

Williams v Compair Maxam [1982] ICR 156James W Cook and Co (Wivenhoe) Ltd v Tipper [1990] ICR 716Haycocks v ADP RPO UK [2023] EAT 129Haycocks v ADP RPO UK Ltd [2024] EWCA Civ 1291R v British Coal Corporation ex p Price [1994] IRLR 72Freud v Bentalls Ltd [1983] ICR 77Lloyd v Taylor Woodrow Construction [1999] IRLR 782Taylor v OCS Group Ltd [2006] ICR 1602Mugford v Midland Bank plc [1997] ICR 399Camelot Group plc v Hogg UKEATS/0019/10British Aerospace plc v Green [1995] ICR 1006Mogane v Bradford [2022] EAT 139Software 2000 Ltd v Andrews [2007] IRLR 568Steen v ASP Packaging Ltd UKEAT/0023/13/1707Polkey v A E Dayton Services Ltd [1988] ICR 142

Statutes

ERA 1996 s.98(1)ERA 1996 s.98(2)(c)ERA 1996 s.98(4)ERA 1996 s.139(1)(b)ERA 1996 s.122(2)ERA 1996 s.123(6)ERA 1996 s.94

Case details

Case number
1602469/2024
Decision date
11 December 2024
Hearing type
full merits
Hearing days
3
Classification
contested

Respondent

Sector
public sector
Represented
Yes
Rep type
barrister

Employment details

Role
Finance & Accounts Assistant
Service
4 years

Claimant representation

Represented
No