Cases1400668/2024

Claimant v Severnprint Ltd (In Administration)

13 September 2024Before Employment Judge N J Roperremote video

Outcome

Claimant succeeds

Individual claims

Failure to Inform & Consultsucceeded

The tribunal found that the first respondent failed to comply with section 188 of TULRCA 1992. Although employee representatives were elected on 26 January 2024, there was no consultation about the impending redundancies and the consultation did not begin at least 30 days before the dismissals took effect on 31 January 2024. The respondent dismissed 38 employees as redundant with immediate effect without adequate consultation.

Facts

Severnprint Ltd announced closure on 23 January 2024 and elected 5 employee representatives on 26 January 2024 to represent 38 shift and office workers. On 31 January 2024, all 38 employees at the Ashville Industrial Estate premises were dismissed as redundant with immediate effect when the company entered administration. No meaningful consultation took place despite the election of representatives. 17 individual claims were brought but only 5 were by the elected representatives.

Decision

The tribunal found that the first respondent breached section 188 TULRCA 1992 by failing to conduct consultation at least 30 days before the dismissals. A protective award of 90 days' pay was made for all affected employees. 11 claims were dismissed because those claimants were not elected representatives and therefore lacked standing. One duplicate claim was also dismissed.

Practical note

In collective redundancy situations without a recognised union, only elected employee representatives have standing to bring protective award claims - individual affected employees cannot bring their own claims if representatives have been properly elected.

Legal authorities cited

Statutes

Trade Union and Labour Relations (Consolidation) Act 1992 s.188(1B)Trade Union and Labour Relations (Consolidation) Act 1992 s.188(2)Trade Union and Labour Relations (Consolidation) Act 1992 s.188Trade Union and Labour Relations (Consolidation) Act 1992 s.188(5)Trade Union and Labour Relations (Consolidation) Act 1992 s.188A(1)Trade Union and Labour Relations (Consolidation) Act 1992 s.188(4)Trade Union and Labour Relations (Consolidation) Act 1992 s.188(1)Trade Union and Labour Relations (Consolidation) Act 1992 s.188(1A)

Case details

Case number
1400668/2024
Decision date
13 September 2024
Hearing type
full merits
Hearing days
1
Classification
contested

Respondent

Sector
manufacturing
Represented
No

Claimant representation

Represented
Yes
Rep type
barrister