Cases4105583/2023

Claimant v Openreach Limited

13 May 2024Before Employment Judge L MurphyScotlandin person

Outcome

Partly successful£297

Individual claims

Unfair Dismissalsucceeded

The tribunal found the dismissal unfair due to an unreasonable investigation and procedural defects. The respondent failed to investigate the claimant's allegations about witness bias, the investigating officer gave misleading assurances about outcome, and key evidence (witness statement and GDU data) was not disclosed to the claimant before the disciplinary hearing. The failure to warn the claimant that dismissal was a potential outcome compounded these defects.

Facts

The claimant, a Service Delivery Engineer with around 2 years' service, had a 'Carer's Passport' allowing him to work closer to home due to caring responsibilities for his seriously ill mother. On 30 May 2023, he was working in an underground hole near a petrol station. He failed to use a roller bar (a safety tool to prevent sparks) and did not keep his gas detection unit (GDU) properly positioned while working, though it was switched on. His Patch Manager, John McGown, arrived at the site, observed the failings, and reported them. The claimant was suspended. The investigating officer (the claimant's line manager, David Rafferty) told the claimant during the fact-find that if he showed remorse and his GDU was on, the worst outcome would be a final written warning. The claimant was dismissed for gross misconduct after a disciplinary hearing. Key evidence (a witness statement and GDU data) was not disclosed to him before the hearing, and he was not warned dismissal was a possible outcome.

Decision

The tribunal found the dismissal substantively unfair due to an unreasonable investigation and serious procedural defects: the investigator failed to investigate the claimant's allegations of witness bias, gave misleading assurances about outcome, and did not disclose key evidence. The respondent also failed to warn the claimant that dismissal was a potential outcome. However, the tribunal found an 80% Polkey reduction (the claimant would likely have been fairly dismissed anyway) and a 90% contributory fault reduction (his conduct was culpable and caused the dismissal). The total award was £296.66.

Practical note

Even where an employee's conduct is serious and dismissal would likely have been fair, procedural defects (failure to investigate bias allegations, misleading the employee about likely outcome, non-disclosure of key evidence) can render a dismissal unfair — though substantial Polkey and contributory fault reductions may drastically reduce the award.

Award breakdown

Basic award£203
Compensatory award£94
Pension loss£532
Loss of statutory rights£500

Adjustments

Polkey reduction80%

80% chance the claimant would have been fairly dismissed anyway following a reasonable procedure. The tribunal found the conduct (failing to use roller bar and improperly positioning gas detection unit) was sufficiently serious that dismissal would have fallen within the band of reasonable responses even after a fair investigation.

Contributory fault90%

The claimant's culpable conduct — failing to use the roller bar and failing to ensure his gas detection unit remained properly positioned when working in a hole near a petrol station — was blameworthy and significantly caused or contributed to his dismissal, risking his own and public safety.

Legal authorities cited

Chandhok v Tirkey [2015] ICR 527Pipecoil Technology Ltd v Heathcote UKEAT/0432/11Whelan v Richardson [1998] IRLR 114Foley v Post Office; HSBC Bank Plc v Madden [2000] ICR 1283Sainsbury's Supermarkets Ltd v Hitt [2003] ICR 111Software 2000 Ltd v Andrews [2007] ICR 825BHS v Burchell [1978] IRLR 379Iceland Frozen Foods v Jones [1983] ICR 17Polkey v A E Dayton Services Ltd [1988] ICR 142West Midlands Co-operative Society v Tipton [1986] AC 536Taylor v OCS Group Ltd [2006] EWCA Civ 702Spink v Express Foods Group Ltd [1990] IRLR 320Shrestha v Genesis Housing Association Ltd [2015] EWCA Civ 94ILEA v Gravett [1988] IRLR 497Boys and Girls Welfare Society v Macdonald [1997] ICR 693

Statutes

ERA 1996 s.123(6)ERA 1996 s.122(2)ERA 1996 s.98

Case details

Case number
4105583/2023
Decision date
13 May 2024
Hearing type
full merits
Hearing days
4
Classification
contested

Respondent

Sector
telecoms
Represented
Yes
Rep type
solicitor

Employment details

Role
Service Delivery Engineer
Service
2 years

Claimant representation

Represented
No