Cases3303686/2024

Claimant v The Home Improvement Studio (Trade) Ltd

10 December 2024Before Employment Judge S MooreWatfordremote video

Outcome

Claimant succeeds£13,708

Individual claims

Unfair Dismissalsucceeded

The tribunal found the redundancy was not genuine. The stated reason that the assistant accountant (MU) had resigned with immediate effect was false—she returned seamlessly to a full-time role just days after her supposed departure. The tribunal found no credible evidence of downturn in business, no meaningful outsourcing of the accountancy function, and concluded the dismissal was not for redundancy within s.139(1)(b) ERA. The consultation was predicated on falsehoods and there was no genuine search for alternative employment when work was clearly available.

Unlawful Deduction from Wagessucceeded

The claimant was awarded a £5,000 bonus in June 2023, which became properly payable wages once declared and quantified, per Farrell Matthews & Weir v Hansen and Tradition Securities v Mouradian. The respondent's attempt to retract the bonus in October 2023 was an unlawful deduction under s.13 ERA, as there was no contractual provision, statutory authority, or written agreement permitting withholding of the bonus after it had been declared.

Othersucceeded

The respondent failed to provide the claimant with any written statement of employment particulars as required by s.1 ERA. The tribunal awarded 4 weeks' pay under s.38 Employment Act 2002, rejecting the respondent's argument that issuing contracts was part of the claimant's role.

Facts

The claimant was a part-time qualified accountant employed by a home improvement company from July 2020 to November 2023. In June 2023 she was awarded a £5,000 bonus which she deferred. In October 2023 the respondent told her the assistant accountant (MU) had resigned with immediate effect and her role was at risk of redundancy due to downturn and outsourcing. After two brief consultation meetings, she was dismissed on 7 November 2023. However, MU had not resigned with immediate effect—she returned to a full-time role on 1 November 2023 at nearly double her previous salary. The respondent also retracted the claimant's bonus, alleging she had failed to detect fraud by another employee.

Decision

The tribunal found the redundancy was a sham. The stated reasons—MU leaving, downturn in business, and outsourcing—were false. MU seamlessly transitioned to a full-time role just days later, no credible evidence of downturn or meaningful outsourcing was provided, and the consultation was predicated on falsehoods. The dismissal was unfair. The bonus retraction was an unlawful deduction of wages as the bonus had been declared and quantified. The respondent also failed to provide written employment particulars. All claims succeeded with a total award of £13,707.60, limited by the claimant's failure to adequately mitigate loss.

Practical note

A redundancy dismissal will be unfair where the employer conducts consultation on fundamentally false premises and where the purported reasons for redundancy (assistant's departure, outsourcing) are contradicted by the employer's own subsequent actions (rehiring the assistant, continuing in-house accountancy work).

Award breakdown

Compensatory award£7,600
Unpaid wages£5,000
Loss of statutory rights£400

Award equivalent: 39.6 weeks' gross pay

Legal authorities cited

Farrell Matthews & Weir v Hansen [2005] IRLR 160Tradition Securities and Futures SA v Mouradian [2009] EWCA Civ 60

Statutes

ERA 1996 s.1ERA 1996 s.13ERA 1996 s.139(1)(b)Employment Act 2002 s.38

Case details

Case number
3303686/2024
Decision date
10 December 2024
Hearing type
full merits
Hearing days
2
Classification
contested

Respondent

Sector
construction
Represented
Yes
Rep type
lay rep

Employment details

Role
Accountant and Company Secretary
Salary band
£15,000–£20,000
Service
3 years

Claimant representation

Represented
Yes
Rep type
barrister