“Although it is good practice to plead it expressly where a claim for Smith v Manchester damages is part of the plaintiff’s case, the possible consequences to the plaintiff from his exposure were pleaded, and this clearly gave rise to the consideration of whether a Smith v Manchester award was appropriate …” 20. Accordingly, submits Mr Jones, if the question was whether or not the Tribunal should have raised a claim, albeit that it was not formally pleaded, the answer was that it did not have to be. As to that, he submits that in Tidman v Aveling Marshall Ltd[1977] IRLR 218 the Tribunal recognised that in some circumstances there was a duty on a Tribunal to consider issues even though they had not been raised by the parties. Given the Judgment of the Appeal Tribunal in that case, Kilner-Brown J said at paragraph 5: “We are of the opinion that in future cases it is the duty of an Industrial Tribunal to raise itself the five different categories of compensatory award. …” 21. The five it identified were those which derived (see paragraph 2) from the case of Norton Tool Co Ltd v Tewson[1972] IRLR 86 , being (1) the immediate loss of wages; (2) the manner of dismissal; (3) future loss of wages; and (4) loss of protection in respect of unfair dismissal. To that Kilner-Brown J added a fifth, which was loss of pension rights. Those were the five elements of loss which a Tribunal should direct itself to consider in every case in which compensation was concerned. Therefore, in this particular case, submits Mr Jones, the Tribunal should have looked at future loss. Moreover this is not simply the chains of the past clanking inappropriately in the present because, as recently as 1998, this Tribunal in the case of Langston v Cranfield University[1998] IRLR 172 modified the generally accepted principle that a party will not be permitted to take new points on appeal which could have been ventilated below. It observed that that principle must be seen in the context of cases where a principle is so well established that “an Industrial Tribunal may be expected to consider it as a matter of course”
“These authorities show that, although the appeal tribunal has a discretion to allow a new point of law to be raised or a conceded point to be reopened, the discretion should be exercised only in exceptional circumstances, especially if the result would be to open up fresh issues of fact which, because the point was not in issue, were not sufficiently investigated before the industrial tribunal. In [ Kumchyk v Derby City Council[1978] ICR 1116 ] the appeal tribunal presided over by Arnold J. expressed the clear view that lack of skill or experience on the part of the appellant or his advocate would not be a sufficient reason. …”
“… In Secretary of State for Employment v Newcastle upon Tyne City Council [[1980] ICR 407 ] the appeal tribunal presided over by Talbot J. said that it was wrong in principle to allow new points to be raised, or conceded points to be reopened, if further factual matters would have to be investigated. In Hellyer Brothers Ltd v Mcleod [[1987] ICR 526 ] this court, in a judgment of the court delivered by Slade L.J. which fully reviewed the authorities, was inclined to the view that the test in the appeal tribunal should not be more stringent than it is when a comparable point arises on an ordinary appeal to the Court of Appeal. In particular, it was inclined to the view of Widgery L.J. in Wilson v Liverpool Corporation[1971] 1 WLR 302 , 307, that is, to follow: “the well known rule of practice that if a point is not taken in the court of trial, it cannot be taken in the appeal court unless that court is in possession of all the material necessary to enable it to dispose of the matter fairly, without injustice to the other party, and without recourse to a further hearing below.” ” 25. In Glennie v Independent Magazines UK) Ltd[1999] IRLR 719 CA, EAT Familiar Authorities 10, Laws LJ, in his decision agreeing with Brooke and May LJJ accepted that, although the Appeal Tribunal possessed a discretion which had to be exercised in accordance with established principles to allow a new point to be raised before it for the first time: “18. … It is a general principle of the law that it is a party’s duty to bring forward the whole of his case at the proper time. The reasoning of Robert Walker LJ in Jones v Governing Body of Burdett Coutts School[1998] IRLR 521 is, with great deference, consonant with this. A new point ought only to be permitted to be raised in exceptional circumstances, as Robert Walker LJ held at p.44B. If the new issue goes to the jurisdiction of the Employment Appeal Tribunal below, that may be an exceptional circumstance, but only, in my judgment, if the issue raised is a discrete one of pure or hard edged law requiring no or no further factual inquiry. There is a public interest, beyond the interests of individual parties, that statutory tribunals exercise the whole of but exceed none of the jurisdiction which Parliament has given them upon such facts as are proved or admitted before them. I do not consider that this case falls within that category, even if the facts required to be ascertained in order to determine the date of the termination of the applicant’s employment were now capable of agreement. On the facts agreed before the industrial tribunal, that tribunal was correct to hold that it lacked jurisdiction. It was therefore necessary to show exceptional circumstances if the Employment Appeal Tribunal was properly to decide to allow the new point to be taken. The Employment Appeal Tribunal identified no such exceptional circumstances. In my judgment, there are none.” 26. The learning was collected together by HHJ McMullen in Secretary of State for Health v Rance[2007] IRLR 665 , EAT Familiar Authorities 11, in particular where he drew together the principles which were applicable at paragraphs 50 and 51. He repeated the points which emerge from the citations I have just made. He considered the circumstances in which a point might be taken. None of those particular points seems to me to be particularly apposite to the present case. He gave examples where the discretion should not be exercised. It is possible that that at 7(b), lack of skill by a represented party, might have something to say in the present case, although I rather doubt it. But otherwise this seems to have little to say in the other direction. I am left with the general statements of principle which I have identified. 27. The central point that Mr Jones makes in answer to those propositions as to proper procedure recognises that the argument was not put forward before the Tribunal. It was not suggested that the Tribunal should make an award of a sum of money in respect of the difficulty which the Claimant now had on the open labour market. As I have noted, that was not his case. The references which were analysed by the Tribunal in respect of injury to feelings were relevant to whether he had appropriately mitigated his loss, a matter which as it happens was not in contention, and as to the level of award which the Tribunal should make to him in respect of his damages including injury to feelings. It was plainly relevant to the latter. It might also (and Mr Jones would submit obviously) be capable of being relevant to the argument that an award for some future loss should and could have been made on that basis. Therefore, he submits that this an exceptional case. Though he did not quite put it this way, it might have been said that the Tribunal was blowing hot and cold at one and the same time in respect of the same evidence. The Tribunal did not appear to appreciate, he submits, that it could have made such an award. It appears to have thought it was precluded by its conclusion that the employment relationship would have terminated in any event on14 November 2013 . 28. The Employment Tribunal here had considered each and every factor which was relevant because it had actually looked at the evidence. It was not therefore a case in which to allow the point to be taken on appeal would involve the court having to look at fresh matters of evidence. These facts were truly exceptional. 29. In response Mr Powell argued that this was not an exceptional case. It was not one where the point had simply been missed by a Tribunal which ought, by reason of its other findings of fact, to have addressed it. It was a case in which central to the decision was the fact that the Claimant had run a contrary case. He did not, as he might have done, have said “Look, I cannot get a job on the open market because of the way in which I was discriminated against and in consequence you should pay for my continuing loss of earnings for it is that which causes me to continue to suffer a loss”