Cases1801881/2023

Claimant v Asda Stores Limited

5 March 2024Before Employment Judge D N Jonesremote video

Outcome

Claimant succeeds£24,359

Individual claims

Unfair Dismissalsucceeded

The tribunal found the respondent failed to establish redundancy as the reason for dismissal under section 139 ERA 1996. The employer did not prove the requirement for employees to do work of a particular kind had diminished. The consultation was deficient, with no meaningful written explanation of the restructure, no reasoned response to the claimant's detailed representations, and the decision appeared predetermined. The process fell outside the range of reasonable responses.

Unlawful Deduction from Wagessucceeded

The tribunal carefully assessed the claimant's holiday entitlement year by year from 2019-2022, taking into account Covid-19 carry-over provisions allowing unused leave to be carried forward for 24 months. The tribunal preferred the claimant's evidence about actual days taken over the respondent's inaccurate planners. The claimant was found to have 61 days outstanding, less 5 days paid, leaving 56 days unpaid at termination.

Facts

The claimant was employed by Asda for 16 years. In October 2021 he was appointed to the newly created permanent role of George Future Lead, Ecommerce, with a retention bonus payable in April 2023. On 7 September 2022, without prior warning, his manager Emma Ford informed him the role was redundant as the team (now 400 strong) had been upskilled and the SME role was no longer needed. After five consultation meetings where the claimant presented detailed representations about why his role was still essential, he was dismissed on 19 October 2022. The claimant also claimed 56 days' unpaid holiday arising from Covid-19 carry-over provisions.

Decision

The tribunal found the dismissal unfair. The respondent failed to establish redundancy as it did not prove the requirement for the claimant's type of work had diminished — only that others might now do it. The consultation was deficient: no written business case, no meaningful response to the claimant's comprehensive representations, and the process appeared predetermined. The tribunal awarded the claimant 56 days' outstanding holiday pay (£22,207.64) plus interest, and listed the case for a remedy hearing on unfair dismissal.

Practical note

Employers asserting redundancy must prove the statutory definition — that the requirement for employees to do work of a particular kind has diminished — not merely that a restructure is proposed, and must provide detailed written rationale and genuine consultation with reasoned responses to employee representations.

Award breakdown

Holiday pay£22,208
Interest£2,151

Legal authorities cited

Williams v Compair Maxam [1982] ICR 156R v British Coal Corporation and Secretary of State for Trade and Industry, ex parte Price [1994] IRLR 72King v Eaton Ltd [1996] IRLR 199Moon v Homeworthy Furniture (Northern) Ltd [1997] ICR 117

Statutes

ERA 1996 s.13ERA 1996 s.24(2)ERA 1996 s.98ERA 1996 s.98(2)(c)ERA 1996 s.98(1)ERA 1996 s.98(4)ERA 1996 s.139ERA 1996 s.139(1)

Case details

Case number
1801881/2023
Decision date
5 March 2024
Hearing type
full merits
Hearing days
2
Classification
contested

Respondent

Sector
retail
Represented
Yes
Rep type
barrister

Employment details

Role
George Future Lead, Ecommerce
Service
17 years

Claimant representation

Represented
No