Cases2601769/2024

Claimant v Affinity Renewables Ltd

28 October 2024Before Employment Judge HutchinsonMidlands Eastin person

Outcome

Claimant fails

Individual claims

Automatic Unfair Dismissalnot determined

This was an interim relief application under s.103A ERA 1996 (whistleblowing dismissal). The claimant alleged she was dismissed for making protected disclosures about non-payment of tax, NI and pension. The respondent disputed this, arguing dismissal was for gross misconduct (texting while driving HGV). The judge found the claimant did not meet the high burden of proof required for interim relief and dismissed the application, but made no finding on the underlying merits which will be determined at full hearing.

Facts

The claimant was employed as an HGV driver for five months. She claims she was dismissed after making protected disclosures about the respondent's alleged failure to pay her tax, national insurance, and pension contributions. The respondent denies this and asserts she was dismissed for gross misconduct, specifically for sending text messages while driving an HGV vehicle. The claimant had insufficient service for ordinary unfair dismissal protection but pursued an automatic unfair dismissal claim under whistleblowing provisions.

Decision

The judge dismissed the interim relief application, finding the claimant had not met the high burden of proof required to show she was 'likely' to succeed at a full hearing. The judge noted the claim was hotly contested, that the respondent disputed whether the disclosure qualified for protection (arguing it was a private dispute without public interest element), and that the respondent had an alternative explanation for dismissal (the texting misconduct). The underlying claim will proceed to a full merits hearing.

Practical note

Interim relief applications in whistleblowing cases face a high threshold: claimants must establish at an early stage that they are 'likely' to succeed, including proving the disclosure was in the public interest and was the principal reason for dismissal, even where the respondent offers an alternative explanation.

Legal authorities cited

Ministry of Justice v Sarfraz [2011] IRLR 582Williams v Brown UKEAT/004/19Raja v Secretary of State for Justice UKEAT/1364/09/CEADandpat v University of Bath UKEAT/1408/09/LATaplin v Shippam Limited [1978] IRLR 450

Statutes

ERA 1996 s.43BERA 1996 s.103AERA 1996 s.129ERA 1996 s.128

Case details

Case number
2601769/2024
Decision date
28 October 2024
Hearing type
interim relief
Hearing days
1
Classification
procedural

Respondent

Sector
energy
Represented
Yes
Rep type
lay rep

Employment details

Role
HGV Driver
Service
5 months

Claimant representation

Represented
Yes
Rep type
solicitor