“(1) where it is at least possible to conclude that the employee will, in time, find an equivalently remunerated job (which will be so in the vast majority of cases), loss should be assessed only up to the point where the employee would be likely to obtain an equivalent job, rather than on a career-long basis, and awarding damages until the point when the tribunal is sure that the claimant would find an equivalent job is the wrong approach; (2) in the rare cases where a career-long-loss approach is appropriate, an upwards-sliding scale of discounts ought to be applied to sequential future slices of time, to reflect the progressive increase in likelihood of the claimant securing an equivalent job as time went by; (3) applying a discount to reflect the date by which the claimant would have left the respondent's employment anyway in the absence of discrimination was not appropriate in any case in which the claimant would only voluntarily have left his employment for an equivalent or better job; and (4) in career-long-loss cases, some general reduction should be made, on a broad-brush basis (and not involving calculating any specific date by which the claimant would have ceased to be employed) for the vicissitudes of life such as the possibility that the claimant would have been fairly dismissed in any event or might have given up employment for other reasons .” 61. Although Elias LJ in Wardle opined that career-long-loss cases would be “ rare ”, he made clear that was not because “ the exercise is in principle too speculative ”: “50. … If an employee suffers career loss, it is incumbent on the Tribunal to do its best to calculate the loss, albeit that there is a considerable degree of speculation. It cannot lie in the mouth of the employer to contend that because the exercise is speculative, the employee should be left with smaller compensation than the loss he actually suffers. Furthermore, the courts have to carry out similar exercises every day of the week when looking at the consequences of career shattering personal injuries. Nor do I accept a floodgates argument. The job of the courts is to compensate for loss actually suffered; if in fact the court were to conclude that this required an approach which departed from that hitherto adopted, then we would have to be willing to take that step. … 53. Exceptionally, a tribunal will be entitled to take the view on the evidence before it that there is no real prospect of the employee ever obtaining an equivalent job. In such a case, the tribunal necessarily has to assess the loss on the basis that it will continue for the course of the claimant's working life. Chagger is an example of such a case. By the time the tribunal came to assess compensation in his case he had already been out of a job for some years. The evidence was that he had made every effort to obtain employment in his chosen field, having made countless applications for new employment. There was a suggestion that he had been stigmatised in the eyes of other employers as a result of the manner of his dismissal. He had taken reasonable steps to mitigate his loss by going into teaching. In these circumstances the Tribunal was entitled to conclude that he had suffered permanent career damage and should be compensated accordingly. Where such a loss is established, a tribunal has to undertake that task, however difficult and speculative it may be.” 62. In Wardle , the ET had approached the question of future loss of earnings on a career-long-loss basis, but then reduced the overall sum that would otherwise have been due: first, to reflect its finding that there was an 80% chance that Mr Wardle would have left his employment after a further couple of years in any event; second, to reflect its finding that there was a 70% chance that Mr Wardle would have returned to equivalent employment after a further year. Given the latter finding, the Court of Appeal held that the ET had been wrong to approach compensation on a whole career basis but, even had it been entitled to calculate loss over Mr Wardle’s whole career, observed that the ET would then: “56. … have had to assess what the claimant would have been likely to earn over that period had he not been treated unlawfully compared with what he is now likely to earn. The difference would then be subject to reductions to reflect the vicissitudes of life (eg the possibility that he might have been fairly dismissed anyway or the risk that he would die or might have to retire early) …” 63. As Elias LJ concluded, that was not done by merely applying a reduction to reflect the ET’s finding that there was a 70% chance of Mr Wardle’s obtaining equivalent employment within three years: having recognised that Mr Wardle had a 70% chance of obtaining equivalent employment within three years, the ET’s decision ought also to have allowed for the yet greater chance that he would mitigate his losses over the years that would then follow. On that basis, an ET would need to consider applying an upwards-sliding scale of discounts to sequential future slices of time, to reflect the progressive likelihood of securing an equivalent job over the years. 64. The case-law also makes clear that an ET should maintain a due sense of proportion in terms of the overall award made; as the EAT warned in Cannock : “Tribunals [should] … not simply make calculations under different heads, and then add them up. A sense of due proportion involves looking at the individual components of any award and then looking at the total to make sure that the total award seems a sensible and just reflection of the chances which have been assessed.” (per Morison J, p 950) 65. This is a point emphasised by the Respondent in the present case, in particular in relation to the uplift awarded under section 207A TULRCA . Section 207A (relevantly) provides: “(2) If , in the case of proceedings to which this section applies, it appears to the employment tribunal that— ( a ) the claim to which the proceedings relate concerns a matter to which a relevant Code of Practice applies, ( b ) the employer has failed to comply with that Code in relation to that matter, and ( c ) that failure was unreasonable, the employment tribunal may, if it considers it just and equitable in all the circumstances to do so, increase any award it makes to the employee by no more than 25%.” 66. There was no dispute before the ET that the Acas Code on Disciplinary and Grievance Procedures (2015) (“the Code”) applied in this case and that the Respondent had failed to comply with the Code . Furthermore, the Respondent did not seek to contest that its failure of compliance had been unreasonable or that it would be just and equitable for an uplift to be applied to the ET’s final award. Although not a submission made below, the Respondent now objects that the ET ought not, however, to have proceeded to award a 20% uplift before it had reached any final determination of the actual sum due to the Claimant. 67. On this point, the Court of Appeal’s Judgment in Wardle again provides some assistance, albeit in the context of a different statutory regime. At the relevant time,section 31 of the Employment Act 2002 provided that, save in “ exceptional circumstances ” in which it would be “ unjust or inequitable ” to do so, a failure to comply with a relevant statutory procedure would require the ET to award an uplift of at least 10%, allowing that to be increased by up to 50% if it considered it “ just and equitable in all the circumstances to do so ”
“15. … in my judgment it would be illogical if the size of the award were not also a potentially relevant factor when the tribunal is exercising its discretion whether or not to increase the compensation … . The principle of proportionality is equally applicable in those circumstances. The size of the award ought in an appropriate case to be a factor informing the tribunal's determination of what is just and equitable under that provision. No doubt in most cases where the compensation is modest it will not affect the tribunal's analysis. But in other cases it can be a highly material consideration. 16. It follows that I do not accept the claimant's submission that unless the tribunal finds the case to be exceptional, it cannot have any regard to the amount of the award when exercising its discretion … 17. Mr Jeans [leading counsel for the employer] submitted that if the Tribunal ought to have had regard to this factor and did not, then given the size of the award in this case, its decision was inevitably flawed and for this reason alone must be set aside. The EAT accepted that submission and so do I.” 68. Considering whether the ET had been entitled to apply a 50% uplift in Wardle , Elias LJ first reflected on the purpose of the provision and how this might inform the approach to be adopted. In much of the case-law, section 32 had been seen as essentially punitive but Elias LJ considered it might also have a compensatory element: culpability might not be the only relevant factor, the degree of harm caused (for example, by false allegations of fraud or dishonesty that the employee has to challenge in the ET because of the denial of a fair internal process) could also inform the size of the uplift ( Wardle , paragraphs 19-23). In either case, however, the structure of section 32 required an ET to explain what facts or circumstances surrounding the failure made it just and equitable to go above (or below) the 10% starting point. In this regard, Elias LJ considered it would be “ only in the most egregious of cases ” that an increase to the maximum would be justified ( Wardle paragraph 26). 69. Having established the appropriate uplift, Elias LJ stated that the ET would then need to consider “ how much this involves in money terms ”, observing: “27. … this must not be disproportionate, but there is no simple formula for determining when the amount should be so characterised. However, the law sets its face against sums which would not command the respect of the general public, and very large payments for purely procedural wrongdoings are at risk of doing just that. The EAT referred to the case of HM Prison Service v Johnson[1997] ICR 275 when Smith J, as she then was, observed, with respect to the level of compensation for injury to feelings, that it was necessary to have regard to “the view which members of the public would have to the amount of the award.”
“6 … in fixing the ACAS uplift the Tribunal should … hear evidence about quantum before fixing the appropriate percentage. No doubt in some cases it is not necessary to hear evidence on quantum. If the sums involved are modest the Tribunal may not consider that it is necessary to establish the multiplicand since it can foresee that the final figure will be within an acceptable range. But in some cases, detailed evidence of quantum will be critical. 72. In Banerjee , the ET had initially (and at the invitation of the parties) applied a percentage increase without making any reference to the monetary consequences. It had subsequently reconsidered that decision of its own motion, a course that the EAT considered had been open to the ET, allowing it the opportunity to correct its earlier error in this regard. The Remedy Appeal - Discussion and Conclusions 73. In deciding the appropriate award of compensation, the ET had first to determine whether this was a whole-career-loss case. In most cases it will be inappropriate for an ET to embark upon the exercise of assessing loss over a career lifetime because it will generally be possible to determine the likelihood of the employee obtaining equivalent employment within a shorter time period. If that can be done, an award of compensation up to the time when the employee is likely to obtain that equivalent employment will fairly assess the loss that is likely to be suffered. 74. In the present case, the ET found that “ it is very unlikely that the claimant will be able to return to work at any stage between now and his retirement age ” (ET Remedy Judgment, paragraph 34). It was on that basis that it concluded (adopting the language used in Wardle v Credit Agricole Corporate and Investment Bank[2011] ICR 1290 ) that this was one of those rare cases where it would be appropriate to consider the Claimant’s future losses on a career-long basis. That the ET had in mind the guidance laid down in cases such as Wardle , Vento v Chief Constable of West Yorkshire Police (No. 2)[2003] ICR 318 , and Ministry of Defence v Cannock[1994] ICR 918 , is clear; not only from the language used, but also because it expressly carried out its assessment on the basis of what was likely , rather than on the balance of probabilities. Contrary to the suggestion made in the Respondent’s submissions under the first ground of appeal, this is not a case where it can properly be questioned whether the ET had the correct legal principles in mind when it approached its task. 75. In reaching its decision on this point, the ET was faced with a dispute between the parties’ experts, not as to the diagnosis (on which they were agreed) but as to the prognosis. As Mr Tolley QC acknowledged in his oral submissions, the ET had been entitled to resolve this dispute - as it did - in favour of the expert evidence adduced by the Claimant. Given the ET’s finding on this point, therefore, the Claimant was to be treated as someone who would suffer from moderate PTSD, depression and symptoms of paranoia for the rest of his working life and who would present with various functional impairments as a result, including finding it difficult to leave his house on some days, or to attend to his personal care, or interact with members of the public, as well as experiencing low mood and sleep disturbance. It was on that basis that the ET had to determine whether there was any likelihood of the Claimant obtaining equivalent employment at some point prior to his expected retirement age. 76. As the Respondent points out, neither expert entirely ruled out the possibility of the Claimant re-entering the labour market at some stage. For Dr Sahota, however, that was because he took the view that the Claimant’s condition might improve at some future point; he otherwise declined to opine on questions relating to the Claimant’s potential employability as this was outside his area of expertise. Other than ruling out a return to the prison service, Dr Oyebode also deferred to the expertise of an occupational health assessor. Whilst he offered some opinion as to the Claimant’s possible employability in his oral evidence (“ [employers] don’t employ someone going off every other week ”), he was plainly doing no more than making an obvious observation as to the Claimant’s vulnerability on the labour market; he was not purporting to provide expert occupational health assessment evidence. Although the ET did not, therefore, have the benefit of expert evidence on the question it had to determine (the likelihood of the Claimant’s being able to obtain equivalent employment given the permanency (as the ET had found) of his mental health difficulties), that was not fatal to its ability to carry out the necessary assessment. Indeed, even if it had had the benefit of an occupational health report, the ET would not have been obliged to accept that evidence; the assessment required would always have been a matter for the ET. Moreover, as Mr Tolley QC also acknowledged in oral argument, in carrying out that assessment, this specialist tribunal was entitled to have regard to its own experience of the labour market; as such, it could be taken to be aware both of the legal obligations imposed on putative future employers under theEquality Act 2010 and of the reality of the Claimant’s still being “ very substantially disadvantaged in the labour market … after what would be a very lengthy absence from work with significant mental health issues ” (ET Remedy Judgment, paragraph 29). 77. Given the ET’s permissible acceptance of Dr Oyebode’s evidence as to the permanency of the Claimant’s mental health impairments, it cannot be said that its conclusion - having correctly applied the test of likelihood, rather than that of the balance of probabilities - was perverse. This was “ a rare case ” (per Wardle , paragraph 50) where it was appropriate for the ET to assess compensation over a career lifetime. 78. That, however, is not the end of the challenge posed by the first two grounds of appeal. Even if it is allowed that the ET was entitled to treat this as a career-loss case, the Respondent contends that it then erred in its approach to the assessment of compensation on that basis; in particular, in failing to apply an appropriate discount to take account of the necessarily speculative exercise in which it was engaged. The Respondent’s argument in this regard is essentially put on two bases. First, as was recognised in Wardle (albeit, obiter ), even in a career-loss case, if an ET has found that there is some likelihood of the employee obtaining other work at some stage, that should be recognised by a sliding scale of discounts applied to sequential future slices of time, to reflect the progressive increase in likelihood of that employee securing an equivalent job. Second, the ET was required to reduce any award for future loss of earnings to reflect the vicissitudes of life, which was not done by merely using the 95% average retention figure within the prison service (for those with over five years service). 79. In Wardle , the ET had made a finding that there was a 70% likelihood that the Claimant would obtain an equivalent job within three years. If considering this as a career-loss case, the ET would need to reduce the compensatory award to reflect this finding but that was not achieved by merely applying a 70% reduction after three years: as both the EAT and the Court of Appeal observed, if Mr Wardle had a 70% chance of obtaining equivalent employment after three years, that likelihood must be all the greater over the years that would then follow. It was on that basis that Elias LJ agreed that a more nuanced approach would be required, applying a sliding scale of discounts to sequential future slices of time, to reflect the progressive increase in likelihood of Mr Wardle’s mitigating his loss as the years went on. 80. The scenario thus envisaged in Wardle is not, however, replicated in this case: in this instance, the ET made no finding that the Claimant would be likely to obtain equivalent employment over any period of time. There may, of course, be cases where an ET has found that the employee has suffered a whole career loss and is unlikely to ever obtain equivalent employment, but where it is, nonetheless, appropriate to apply a sliding scale of discounts reflecting a progressive increase in likelihood that they will ultimately be able to obtain some very different employment, quite possibly at a very reduced level of earnings. Had the ET in the present case failed to consider this, I can see that there might be something in the Respondent’s criticism. It is, however, plain that the ET did not omit to countenance this possibility. Rather, it considered whether the Claimant might be able to return to “ any work in the future ” but found that was “ extremely remote ” and would require him to undergo lengthy “ retraining and/or rehabilitation ”, and that he would then still be “ very substantially disadvantaged in the labour market ” (ET Remedy Judgment, paragraph 29). Having reached that view, the ET was entitled to see this as a case where the evidence did not support the application of a sliding scale of discounts, because “ based on the evidence we have heard, it is very unlikely that the claimant will be able to return to work at any stage between now and his retirement age ” (ET Remedy Judgment, paragraph 34). On that basis, the ET concluded that the “ remote prospect of recovery and a return to work ” (Remedy Judgment, paragraph 35) could appropriately be reflected in the overall discount to be applied in this case. That was a permissible conclusion on the evidence and given the ET’s findings in this case. The Respondent’s challenge in this respect is, in reality, an attempt to persuade me to substitute what might be my own assessment for that of the ET; that does not give rise to a proper basis of appeal. 81. The final argument raised in this regard relates, however, to the 5% discount that the ET did apply in this case, which the ET used to take account of both the “ very slight prospect of the claimant retiring from the Service before his pension age ” as well as the “ equally remote prospect ” of his returning to work (ET Remedy Judgment, paragraph 35). 82. As I have already explained, given its findings in this case, I see nothing wrong with the ET’s approach to the discount to be applied for any future possible return to employment. Equally, I am clear that the ET was entitled to find that the prospect of the Claimant voluntarily leaving his work as a prison officer was “ highly unlikely ”
“34. … consideration of a party’s conduct should normally take place both at the stage when the judge is considering what order for costs he should make, and then during assessment. But the court will want to ensure that dishonesty is penalised but that the party is not placed in double jeopardy. …”