“There was a suggestion in argument before the Employment Appeal Tribunal, which was not pursued in this court that the burden of proof in protected disclosure cases should be the same as that applied in equivalent provisions governing discrimination cases. In those cases the burden of proving the reason for less favourable treatment of the Claimant shifts to the Respondent. Mr Linden argued for a "strictly limited" role for discrimination law in protected disclosure cases. The thinking behind the association of protected disclosure and discrimination is that both causes of action involve acts or omissions for a prohibited reason. Unfair dismissal and discrimination on specific prohibited grounds are, however, different causes of action. The statutory structure of the unfair dismissal legislation is so different from that of the discrimination legislation that an attempt at cross fertilisation or legal transplants runs a risk of complicating rather than clarifying the legal concepts. As Mr Linden accepted there simply is no need to resort to the discrimination legislation in order to ascertain the operation of the burden of proof in unfair dismissal cases.” 51. S ection s152 TULRCA 1992 deals with automatic unfair dismissal on trade union grounds and provides as follows: “(1) For purposes ofPart X of the Employment Rights Act 1996 (unfair dismissal) the dismissal of an employee shall be regarded as unfair if the reason for it or, if more than one, the principal reason was that the employee – (a) was, or proposed to become, a member of an independent trade union,… (b) had taken part, or proposed to take part, in the activities of an independent trade union at an appropriate time,… (2) In subsection (1) an “appropriate time” means – (a) a time outside the employee’s working hours, or (b) a time within his working hours at which, in accordance with arrangements agreed without consent given by his employer, it is permissible for him to take part in the activities of a trade union (3) And for this purpose “working hours”, in relation to an employee, means any time when, in accordance with his contract of employment, he is required to be at work.”
“The Tribunal did not consider that any point arose as to the timing of any union activities, to the extent that the Respondents were seeking to prevent or deter the Claimant from taking part in these. Although, as identified in paragraph 73 above, there had been some challenge about when the Claimant had been carrying out such activities, there was no evidence from which the Tribunal could conclude that he had in fact been doing so at an inappropriate time. Nor was there any evidence to suggest that, had he not been suspended, he would have been doing this at an inappropriate time.” (g) At paragraph 147: “The Tribunal concluded that the main purpose of suspending the Claimant and of carrying out the misconduct investigation was to prevent him from carrying out the activities of an independent trade union at an appropriate time. The Complaint of detriment under point K was therefore well founded.” 55. So far as the question of automatic unfair dismissal was concerned, the Tribunal’s reasoning and conclusions were as follows: (a) At paragraph 150 the Tribunal stated that it “concluded that, for substantially the same reasons as given in relation to item K, the Respondent had failed to prove the reason or principal reason for dismissal on which they relied. The Tribunal found that Mr Anderson’s evidence about the letter of14 November 2012 showed that he was not acting independently in the disciplinary process, and was following the directions of the Respondent’s HR department. In particular, it could be seen that again Mr Whitefoot was involved: he had approved the 14 November letter”. (b) At paragraph 151 the Tribunal stated that it took account of the points set out at paragraphs 144 and 145, and its finding that the Respondent had not discharged the burden of proof in relation to the detriment complaint. It went on to state: “The decision to dismiss the Claimant followed directly from the suspension and decision to investigate the conduct allegations. In spite of the evidence from Mr Anderson and Mr Whitefoot, the Tribunal found it improbable that the latter had not influenced the decision to dismiss the Claimant. The only identifiable reason why Mr Whitefoot would do so was the Claimant’s union activities. On 8 June Mr Whitefoot had predicted or threatened disciplinary proceedings that would be delayed until after the Olympics (paragraph 75 above). He was closely concerned with trade union issues and the risk of a strike in particular.” (c) The Tribunal accordingly concluded that: “… The principal reason for the Claimant’s dismissal was that he had taken part or proposed to take part in the activities of an independent trade union at an appropriate time and the dismissal was therefore automatically unfair.” (d) Contributory fault and Polkey were held not to apply because the Employment Tribunal had rejected the Respondent’s stated reason for dismissal. The grounds of appeal 56. The appeal against the Tribunal’s findings is extensive. Ms Chudleigh has rightly reminded me of the observations in Aslef v Brady[2006] IRLR 576 at [55] (Elias P, as he then was) as to the importance of this Tribunal respecting the factual findings of an employment tribunal. The Employment Appeal Tribunal is not entitled to identify an error of law merely because it would have reached a different factual conclusion; nor should the reasons of a tribunal be subject to unrealistically detailed scrutiny. Tribunals are not required to make findings of fact on all matters of dispute; nor to recount all the evidence. It cannot therefore be assumed that the findings of fact reflect all the evidence, still less the nuances of expression used by witnesses who gave evidence. An infelicity of expression and even a factual or legal error in a particular sentence will not render a tribunal’s decision defective if the tribunal has essentially properly directed itself. 57. On that basis I turn to consider the grounds of appeal. Twelve grounds are advanced by the Respondent, said individually or cumulatively to vitiate the Tribunal’s judgment. The first five grounds relate to the findings in relation to suspension and the disciplinary investigation; grounds six to 10 are directed at the finding of automatic unfair dismissal contrary to section 152(1); and the remaining grounds concern Polkey and contributory conduct. Grounds 1 to 3 58. I take these grounds together because there is overlap in the Tribunal’s reasoning in relation to the matters challenged in these grounds. Ground 1 challenges the Tribunal’s approach to the burden of proof: in relation to the complaint that the Claimant’s suspension and disciplinary investigation constituted a detriment contrary to s. 146(1)(b), in considering what the Respondent’s main purpose was, the Tribunal misapplied the burden of proof provisions in failing to evaluate the Respondent’s explanations for the treatment or to make relevant findings of fact. Ground 2 asserts an error of law in treating Mr Caffrey as an appropriate comparator for assessing whether the Claimant was treated inconsistently. Ground 3 challenges the reliance on by the Tribunal as a factor relevant to determining whether the Respondent discharged the burden of proof, the unexplained delay in the disciplinary process – the Respondent contends that this was not addressed in evidence because it was not identified as detrimental treatment. 59. Mr Sutton emphasises that the Tribunal made no finding in relation to the veracity of the accounts given that the Claimant acted in a threatening way on6 July 2012 and that the reason for the decision to suspend him was directly influenced by concerns in relation to staff safety as a consequence of the incident. Moreover, although when dealing with the letter of9 July 2012 notifying the Claimant of his suspension, the Tribunal identified that the suspension was said to be on the grounds of “aggressive, intimidating and totally unwarranted” conduct and its implications for the safety of the Claimant and his co-workers, the Respondent argues that there was no evaluation of the incident on6 July 2012 and whether Mr Caffrey’s characterisation of it was accurately stated by him. Such an evaluation was Mr Sutton argued, manifestly necessary in order to decide whether or not the main purpose of the Respondent in suspending or investigating was the improper purpose. 60. Against that Ms Chudleigh points to paragraphs 144 to 147 and submits that a correct direction in law was given; the Tribunal approached the burden of proof correctly and expressly acknowledged at paragraph 144 that on the face of it there was misconduct to investigate. This was, she submitted, a case of pretext, and the Tribunal made adequate findings of fact and is not to be criticised for infelicities of expression or by applying a fine tooth comb to its reasoning. 61. The critical passages in the Reasons relating to these grounds are paragraphs 144 and 145. These have been summarised above. On the evidence and the Tribunal’s findings, those directly involved in the suspension decision were Mr Caffrey, Ms Butler and Mr Whitefoot; whereas, the Tribunal found that Mr Cadger was appointed by Mr Adamson to investigate the allegations and counter-complaints, and it was on Mr Cadger’s recommendation that disciplinary charges were issued. The critical question for the Tribunal was whether the main purpose these individuals had in doing what they did, was preventing or deterring the Claimant from taking part in trade union activities at an appropriate time. The Tribunal did not distinguish between these decision-makers as it should have done, since a consideration of their thought processes to discern what object they sought to achieve was necessary. Particularly stark is the absence of any evidence to support or finding that Mr Cadger was influenced or affected by any improper purpose of the others, or of his own. Instead, the Tribunal dealt with these separate acts together and without any focus at all on Mr Cadger’s role in the latter decision. 62. The Tribunal identified (at paragraph 144) two competing purposes of the suspension and investigation: the fact that there was misconduct by the Claimant to investigate, as the Respondent contended; and removing him from the workforce at a time when strike action was being contemplated to coincide with the Olympics, as the Claimant contended. If the Claimant raised an arguable case of an ulterior purpose, it was for the Respondent to prove the (main) proper purpose for which it acted. If the Tribunal was not satisfied by the Respondent’s evidence that the main purpose was as it asserted, it did not follow that the Tribunal was bound (on any basis, whether as a matter of law or logic) to conclude that the purpose was that identified by the Claimant ( Kuzel ). The Respondent’s main purpose would need to be determined by reference to the evidence, the findings of fact and the inferences that could properly be drawn from those facts. 63. Even if there was genuine misconduct by the Claimant, if the Respondent was acting opportunistically in relying on this misconduct (in circumstances where others would not have been similarly treated) it would be open to the Tribunal to conclude that despite the misconduct, the Respondent’s true purpose in acting as it did was a different purpose. However, it would not be enough for the Tribunal to find that the relevant decision-makers merely welcomed the opportunity to suspend and investigate the Claimant for misconduct because he was associated with the Olympics strike; to succeed, the Tribunal had to find that their main purpose in doing so was to prevent or deter him from these activities: see The Co-operative Group Ltd v Baddeley[2014] EWCA Civ 658 (Underhill LJ) at 43. Provided that the main purpose in acting as they did was the misconduct, the fact that they may have been pleased about this is insufficient. 64. At paragraph 17 of the Reasons, the Tribunal directed itself in relation to Yewdall as discussed above, and also that “the burden of proof only passes to the employer after the employee has established a prima facie or arguable case of unfavourable treatment on the prohibited grounds which requires to be explained”
“After this altercation with Zak, Mick and I telephoned John Whitefoot….to explain what had happened. I was aware there had been trade union activity and that John Whitefoot had been dealing with this. I did not want to tread on anyone’s toes by doing anything that may upset what had been happening with the trade unions”
“he was closely concerned with trade union activities and the risk of a strike in particular”