Leacy v Building Craft College [2022] EAT 59

The Employment Appeal Tribunal (EAT) dismissed the claimant's appeal, determining that the Employment Tribunal's (ET) conduct and conclusions were both fair and adequately supported by the facts presented.

Key Principles:

  1. An ET is expected to ensure a fair hearing process, especially when discriminatory constructive dismissal claims are made.

  2. The ET's conclusions must be grounded in facts and should be justifiable.

  3. Judgements should comply with the 'Meek' standards, ensuring that the reasoning behind the decisions is clearly articulated.

Facts and Application of Law

The claimant asserted that he had disclosed his mental health disability to the respondent early in his employment. Following his disclosure, he believed he faced multiple detriments. The respondent's subsequent actions, which included placing the claimant on medical suspension and how they addressed his grievances, ultimately led him to resign. This led him to argue he was subjected to discriminatory constructive dismissal.

However, at the ET, the claimant's contentions were not upheld. Unsatisfied with this outcome, he appealed to the EAT, asserting that the ET's hearing was substantively unjust.

Upon review, the EAT found no fault in how the ET managed the hearing. The ET's determinations were rooted in the evidence provided, and its judgement met the standards set out in the 'Meek' criteria. As a result, the claimant's appeal was dismissed, reinforcing the importance of fair and evidence-based decision-making in Employment Tribunal cases.

For individuals looking to challenge Employment Tribunal decisions at the EAT, this case underscores the need for a robust evidential basis and the importance of understanding the standards against which decisions are assessed.

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Citizens Advice Merton & Lambeth v Mefful [2022] EAT 11