Cases2300351/2023

Claimant v John Steward Transport Limited

23 February 2024Before Employment Judge VarnamLondon Southremote video

Outcome

Claimant succeeds£10,090

Individual claims

Unfair Dismissalsucceeded

The tribunal found that the respondent dismissed the claimant by telling him to 'pack your stuff and go' if he refused to drive a particular lorry. The dismissal was procedurally unfair because the respondent conducted no investigation, engaged in no disciplinary procedure, and failed entirely to address the claimant's genuine concerns about using a remote-controlled crane with which he had little practical experience. The decision to dismiss fell outside the range of reasonable responses available to a reasonable employer.

Facts

The claimant, an HGV driver employed for 5.5 years, arrived at work on 11 October 2022 to find his usual lorry undergoing repair. The workshop manager brusquely ordered him to drive a colleague's lorry equipped with a remote-controlled crane, a type the claimant was qualified to use but had little practical experience with and genuine concerns about. After the claimant refused and a confrontation ensued in which both men squared up to each other, the compliance manager conveyed the director's ultimatum: 'either take the truck out now, or you can pack your stuff and go'. The claimant left and never returned.

Decision

The tribunal found the claimant was dismissed, not resigned. The words 'pack your stuff and go' amounted objectively to dismissal. The dismissal was unfair because the respondent conducted no investigation into the claimant's genuine concerns about using unfamiliar equipment, followed no disciplinary procedure, and gave him no opportunity to respond. Awards reduced by 25% for contributory fault (claimant's confrontational conduct with the manager) but no Polkey reduction as the director's own evidence was he would not have dismissed. 10% ACAS uplift and section 38 award for failure to provide written terms.

Practical note

Even where dismissal arises from confrontation and refusal to follow instructions, wholesale procedural failures—particularly failing to investigate an employee's genuine safety or capability concerns before dismissing—will render the dismissal unfair, though contributory conduct reductions may still apply.

Award breakdown

Basic award£3,212
Compensatory award£6,878
Pension loss£425
Loss of statutory rights£500

Adjustments

Contributory fault25%

Claimant contributed to his dismissal by unnecessarily escalating a confrontation with the workshop manager Mr Cole, threatening to knock him out and squaring up to him. However, the tribunal found the majority of fault rested with the respondent.

ACAS uplift+10%

Respondent wholly breached the ACAS Code on Disciplinary and Grievance Procedures by conducting no procedure whatsoever before dismissing the claimant.

Legal authorities cited

Polkey v A E Dayton Services Ltd [1988] ICR 142Martin v MBS Fastenings (Glynwed) Distribution Ltd [1983] IRLR 198BHS v Burchell [1978] IRLR 379Sainsbury's Supermarkets Ltd v Hitt [2003] ICR 111Norton Tool Company Limited v Tewson [1972] ICR 501Rodgers v Leeds Laser Cutting Ltd [2023] ICR 356Lenlyn UK Limited v Kular (2016) UKEAT/0108/16

Statutes

ERA 1996 s.123(6)TULRCA 1992 s.207AEmployment Act 2002 s.38ERA 1996 s.98ERA 1996 s.100(1)(d)

Case details

Case number
2300351/2023
Decision date
23 February 2024
Hearing type
full merits
Hearing days
1
Classification
contested

Respondent

Sector
transport
Represented
Yes
Rep type
lay rep

Employment details

Role
HGV driver
Service
6 years

Claimant representation

Represented
No