Cases2500586/2023

Claimant v Tolent Construction Limited

26 June 2024Before Employment Judge ArullendranNorth Easton papers

Outcome

Default judgment

Individual claims

Failure to Inform & Consultsucceeded

The respondent entered administration and dismissed 20 or more employees as redundant from February 2023. There was no proper warning or consultation undertaken with a recognised trade union or the claimant. No employee representatives had been elected or appointed for consultation as required by section 188A of the 1992 Act. The tribunal found the respondent in breach of its duty under section 188 of the Trade Union and Labour Relations (Consolidation) Act 1992 and awarded the maximum protective period of 90 days.

Facts

Tolent Construction Limited entered administration on 13 February 2023 and dismissed 20 or more employees as redundant from its Gateshead premises. The first dismissal took effect on 13 February 2023. The respondent failed to provide any proper warning or consultation with a recognised trade union or with the claimant. No employee representatives were elected or appointed for consultation as required by law. The respondent initially defended the claim but withdrew its defence on 16 May 2024.

Decision

The tribunal found the respondent in breach of section 188 of the Trade Union and Labour Relations (Consolidation) Act 1992 for failing to inform and consult about the collective redundancy. The tribunal made a protective award under section 189 for the maximum period of 90 days beginning on 10 March 2023. This was a Rule 21 default judgment entered on the papers without a hearing as the respondent ceased to defend the claim.

Practical note

Employers in administration remain bound by collective consultation requirements under section 188 TULRCA 1992, and failure to consult will result in a protective award of up to 90 days' pay.

Legal authorities cited

Statutes

Trade Union and Labour Relations (Consolidation) Act 1992 s.188Trade Union and Labour Relations (Consolidation) Act 1992 s.188ATrade Union and Labour Relations (Consolidation) Act 1992 s.189Employment Protection (Recoupment of Jobseekers Allowance and Income Support) Regulations 1996

Case details

Case number
2500586/2023
Decision date
26 June 2024
Hearing type
rule 21
Hearing days
Classification
default

Respondent

Sector
construction
Represented
No

Claimant representation

Represented
No