Cases1400519/2022

Claimant v Royal Mail Group

25 May 2024Before Employment Judge HallidayBristolremote video

Outcome

Partly successful

Individual claims

Direct Discrimination(disability)failed

The tribunal found no evidence that the Claimant was treated less favourably because of his depression. The failure to appoint him to roles was due to proper application of agreed selection processes. There was no link between his disability and the treatment he received; the respondent had reasonable and proper cause for its actions.

Constructive Dismissalsucceeded

The tribunal found a series of cumulative breaches from 30 November to 13 December 2021 destroyed trust and confidence: failure to acknowledge and properly handle the grievance, miscommunication about meetings, failure to reschedule when aware the Claimant had a medical appointment. This was an effective cause of resignation. The Claimant did not affirm the contract by remaining off sick and pursuing the grievance.

Facts

Claimant, an experienced postman employed since 2013, undertook significant additional duties including training without extra pay. He applied for two internal roles (PHG and Workplace Coach) but was unsuccessful. He raised a grievance on 25 November 2021 while off sick with stress. The respondent failed to acknowledge the grievance promptly, sent confusing communications about grievance meetings, and maintained a scheduled meeting on 13 December despite knowing the Claimant had a medical appointment. The Claimant resigned on 3 February 2022, having secured alternative employment.

Decision

The tribunal dismissed the disability discrimination claim, finding no link between the Claimant's depression and the treatment he received in recruitment processes. However, the constructive dismissal claim succeeded. The tribunal found the respondent's cumulative failures in handling the grievance between 30 November and 13 December 2021 breached the implied term of trust and confidence. This was an effective cause of resignation; the Claimant had not affirmed the contract by remaining off sick and pursuing the grievance.

Practical note

Employers must handle grievances promptly and clearly, especially when an employee is off sick with stress; systemic HR failures in acknowledging and processing a grievance can constitute a repudiatory breach even if no individual act was deliberately malicious.

Legal authorities cited

Madarassy v Nomura International Plc [2007] ICR 867Western Excavating v Sharp [1978] ICR 221Malik v Bank of Credit and Commerce International [1998] AC 20Omilaju v Waltham Forest London Borough Council [2005] IRLR 35Kaur v Leeds Teaching Hospital NHS Trust [2018] EWCA

Statutes

Employment Rights Act 1996 s.95(1)(c)Equality Act 2010 s.136Equality Act 2010 s.13

Case details

Case number
1400519/2022
Decision date
25 May 2024
Hearing type
full merits
Hearing days
3
Classification
contested

Respondent

Sector
public sector
Represented
Yes
Rep type
solicitor

Employment details

Role
Operational Postal Grade (OPG)
Service
8 years

Claimant representation

Represented
No