Cases2217707/2023

Claimant v McCarthy Tétrault LLP

5 June 2024Before Employment Judge AnthonyLondon Centralremote video

Outcome

Claimant succeeds

Individual claims

Unfair Dismissalsucceeded

The tribunal found that the respondent failed to prove redundancy was the reason for dismissal. The evidence showed the respondent continued to offer full-time employment at reduced salary until March 2023, indicating no diminished requirement for litigation work. The 2022 feedback form was positive about future work prospects. The tribunal concluded redundancy was only articulated after negotiations to vary contract terms failed, and the respondent provided no cogent explanation for what changed between offering alternative employment and withdrawing it. The respondent failed to establish a genuine redundancy situation existed.

Facts

The claimant was an Income Partner specialising in litigation and international arbitration, employed since November 2018 on £320,000 per annum with a target of 1,400 billable hours annually. From December 2022 the respondent sought to reduce his salary to £110,000 and hours to 460, citing underbilling since 2018. This offer remained available until withdrawn in April 2023. The respondent then commenced redundancy consultation, stating there was insufficient litigation work. The claimant's employment was extended to August 2023 to complete work on Ugandan litigation. The respondent refused a further extension despite improved billing projections.

Decision

The tribunal found the dismissal was unfair because the respondent failed to prove redundancy was the genuine reason. The respondent continued offering full-time employment at reduced salary until March 2023, inconsistent with a genuine redundancy. The 2022 feedback form was positive about future litigation work. The tribunal concluded redundancy was only raised after contract variation negotiations failed, and the respondent provided no evidence of what changed to make the alternative employment arrangement unviable by April 2023. The claim succeeded.

Practical note

Employers cannot rely on redundancy as the reason for dismissal where they have consistently offered continued full-time employment on varied terms, and where contemporaneous performance reviews contradict any assertion that the requirement for employees to do that type of work has diminished.

Legal authorities cited

Safeway Stores Plc v Burrell [1997] ICR 523Murray v Foyle Meats Ltd [2000] 1 AC 51Baxter v Limb Group of Companies [1994] IRLR 572Sutton v Revlon Overseas Corporation Ltd [1973] IRLR 173Bromby and Hoare Ltd v Evans [1972] ICR 113James W Cook & Co (Wivenhoe) Ltd v Tipper [1990] ICR 716Johnson v Nottinghamshire Combined Police Authority [1974] ICR 170Loy v Abbey National Financial and Investment Services plc [2006] SLT 761Mitie Olscot Ltd v Henderson EAT 0016/04Abernethy v Mott, Hay and Anderson [1974] ICR 323Williams v Compair Maxam [1982] ICR 156

Statutes

ERA 1996 s.98(2)ERA 1996 s.98(4)ERA 1996 s.139(1)ERA 1996 s.139(1)(b)ERA 1996 s.98

Case details

Case number
2217707/2023
Decision date
5 June 2024
Hearing type
full merits
Hearing days
2
Classification
contested

Respondent

Sector
legal services
Represented
Yes
Rep type
barrister

Employment details

Role
Income Partner
Salary band
£100,000+
Service
5 years

Claimant representation

Represented
Yes
Rep type
barrister