Cases4105605/2024

Claimant v Bristow Helicopters Ltd

Outcome

Other

Individual claims

Automatic Unfair Dismissalnot determined

This was an interim relief hearing. The tribunal refused the application because the claimant did not meet the high threshold of showing a 'pretty good chance of success'. There were preliminary issues about whether the disclosure qualified for protection under s.43B, whether it was in the public interest, and whether it was the reason for dismissal. The respondent had a stateable defence that dismissal was due to unsatisfactory performance during probation.

Whistleblowingnot determined

The claimant alleged he made a protected disclosure on 20 March 2024 complaining of ongoing bullying to the HR Director. The tribunal identified preliminary issues including whether this qualified as a protected disclosure under s.43B, whether it was made in the public interest rather than being a private employment dispute, and whether the claimant had a reasonable belief. These issues remain to be determined at a full hearing.

Facts

The claimant, who lacked two years' service for ordinary unfair dismissal, claimed automatic unfair dismissal for making a protected disclosure. He alleged he complained anonymously about ongoing bullying to the HR Director on 20 March 2024, identifying himself on 5 June 2024. He was dismissed during a probationary review. The respondent's witnesses stated his performance was unsatisfactory during probation and the decision-maker was unaware of any complaint.

Decision

The tribunal refused the interim relief application. The judge found the claimant had not met the high threshold of showing a 'pretty good chance of success'. There were preliminary issues about whether the disclosure qualified for protection, whether it was in the public interest, and whether it caused the dismissal. The respondent had a stateable defence that dismissal was for unsatisfactory probationary performance.

Practical note

Interim relief applications in whistleblowing dismissal cases require near-certainty of success, and will fail where there are preliminary issues about whether a disclosure qualifies for protection and where the employer has a credible alternative explanation for dismissal.

Legal authorities cited

Taplin v C Shippam Ltd [1978] IRLR 450Ministry of Justice v Sarfraz [2011] IRLR 562

Statutes

ERA 1996 s.43BERA 1996 s.103AERA 1996 s.128-132

Case details

Case number
4105605/2024
Decision date
12 July 2024
Hearing type
preliminary
Hearing days
1
Classification
procedural

Respondent

Sector
transport
Represented
Yes
Rep type
solicitor

Claimant representation

Represented
No