Cases3200997/2023

Claimant v Motability

7 November 2024Before Employment Judge Suzanne PalmerLondon Centralin person

Outcome

Claimant fails

Individual claims

Constructive Dismissalfailed

The tribunal found that the claimant resigned and was not dismissed. Only two procedural flaws were established: failure to provide interview transcripts and failure to interview MS (a colleague). The tribunal concluded these flaws, individually or cumulatively, were not sufficient to breach the implied term of trust and confidence. The claimant was able to understand and answer allegations against her, and the disciplinary process viewed as a whole was conducted fairly and reasonably. The tribunal also found that the claimant had misunderstood comments by Mr Mitchell regarding the seriousness of the sanction, and there was no evidence he indicated a predetermined outcome.

Facts

The claimant was a Customer Care Manager for Motability, responsible for assessing funding applications. A disciplinary investigation was initiated after it emerged that she had been sending work to a colleague (MS) in a different team, who would draft Decision Records which the claimant would then copy largely unchanged into the system. MS's managers had been aware he was offering help to others and had asked him to stop. The claimant maintained she did not realise this was wrong, that MS volunteered to help, and that she retained ownership of all decisions. She resigned during sick leave for stress before the disciplinary outcome (which would have been a first written warning) was communicated.

Decision

The tribunal dismissed the constructive dismissal claim. It found only two procedural flaws: failure to provide interview transcripts from the MS investigation and failure to interview MS during the investigation. These flaws related to potential mitigation evidence rather than exculpatory evidence. Viewed objectively and in the round, the disciplinary process was fair and reasonable, and these isolated flaws did not breach the implied term of trust and confidence or entitle the claimant to resign.

Practical note

Minor procedural flaws in a disciplinary investigation (such as failure to provide all underlying evidence or interview a witness) will not amount to constructive dismissal where the employee can understand and answer the allegations and the process as a whole is fair and reasonable.

Legal authorities cited

Omilaju v Waltham Forest London Borough Council [2005] IRLR 35 CABuckland v Bournemouth University Higher Education Corporation [2010] IRLR 445 CAKaur v Leeds Teaching Hospital NHS Trust [2018] IRLR 833 CAWorking Men's Club and Institute Union Ltd v Balls UKEAT/0119/11/LAMalik v Bank of Credit and Commerce International [1998] AC 20Gogay v Hertfordshire County Council [2000] IRLR 703Western Excavating v Sharp [1978] ICR 221

Statutes

ERA 1996

Case details

Case number
3200997/2023
Decision date
7 November 2024
Hearing type
full merits
Hearing days
3
Classification
contested

Respondent

Sector
charity
Represented
Yes
Rep type
barrister

Employment details

Role
Customer Care Manager
Service
4 years

Claimant representation

Represented
Yes
Rep type
barrister