Case 2300752/2023 · Employment Tribunal

Mr. A. McManus and Others v SC Realisations 2023 Limited (In Administration) — 2025

Case reference: 2300752/2023
Decision date: 20 February 2025
Jurisdiction: England & Wales
Judge: Employment Judge Sudra
Venue: London South

Indexed: 23 May 2026

Parties

2 named

Claimant

Mr. A. McManus and Others

Respondent

SC Realisations 2023 Limited (In Administration)

Key findings

Tribunal's reasoning

The tribunal found the Claimants' complaints under section 189 of the Trade Union and Labour Relations (Consolidation) Act 1992 well founded. The claim concerned the Respondent's failure to comply with the consultation requirements in section 188 of TULR(C)A 1992 in relation to the dismissals that took effect on 23 January 2023.

The tribunal ordered, by way of a protective award under section 189(3) of TULR(C)A 1992, that the Respondent pay remuneration to the Claimants named in the attached schedule for a protected period of 90 days beginning on 23 January 2023. The judgment records that the Employment Protection (Recoupment of Jobseeker's Allowance and Income Support) Regulations 1996 apply to the award.

The written notes explain that this is a two-stage process and that the tribunal at this stage makes no financial award, only a judgment that the Claimants are entitled to a protective award in the terms set out. If payment is not made, or if there is a dispute about the amount payable, that matter would be dealt with separately under section 192 of TULR(C)A 1992.

Claims and outcomes

1 finding recorded

Claim type	Issue or finding	Outcome	Protected characteristic	Award
Trade union	Complaint under section 189 TULR(C)A 1992 that the Respondent failed to comply with section 188 TULR(C)A 1992. The tribunal made a protective award but did not quantify a financial sum in this judgment.	Upheld	—	—

Legal tests applied

4 references

Official outcome judgment PDF

Gov.uk primary record

The official judgment PDF on gov.uk contains the tribunal's outcome, reasoning, and any remedy details. Where this page does not yet show extracted outcomes for every claim, use the PDF as the authoritative source.

Open official judgment PDF on gov.uk

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How we got this data

Case essentials (reference, date, judge, venue, country, claim categories) are extracted from the structured metadata gov.uk publishes alongside each decision. Parties and monetary figures are extracted from the judgment PDF text. Key findings and per-claim outcomes require a second extraction pass that is not yet complete for this case — until then, the primary source linked above is the authoritative record. See full methodology.

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