Cases1805504/2023

Claimant v Propel Tech Limited

Outcome

Claimant fails

Individual claims

Unfair Dismissalstruck out

The claimant lacked the necessary two years' qualifying service required under section 108 of the Employment Rights Act 1996. The claimant's argument that non-compliance with the ACAS code constituted an automatically unfair dismissal was rejected as this is not a relevant statutory right under section 104(4) ERA 1996.

Wrongful Dismissalnot determined

The wrongful dismissal claim was unaffected by the strike-out of the unfair dismissal claim and remains listed for hearing with a reduced time estimate of 3 hours.

Facts

The claimant brought an unfair dismissal claim after being dismissed by Propel Tech Limited. The claimant had less than two years' service with the respondent. The claimant attempted to argue that the respondent's alleged failure to comply with the ACAS code of practice meant the dismissal should be considered automatically unfair.

Decision

The tribunal struck out the unfair dismissal claim because the claimant lacked the required two years' qualifying service under section 108 ERA 1996. The tribunal rejected the claimant's argument that ACAS code non-compliance could give rise to an automatic unfair dismissal claim under section 104(1). The wrongful dismissal claim remains listed.

Practical note

Breach of the ACAS code does not constitute a 'relevant statutory right' under section 104(4) ERA 1996 and cannot found an automatic unfair dismissal claim to circumvent the two-year qualifying service requirement.

Legal authorities cited

Statutes

ERA 1996 s.108ERA 1996 s.104(1)ERA 1996 s.104(4)

Case details

Case number
1805504/2023
Decision date
6 February 2024
Hearing type
strike out
Hearing days
Classification
procedural

Respondent

Sector
technology
Represented
No

Employment details

Service
2 years

Claimant representation

Represented
No