Mrs E Grisdale v Association of British Dispensing Opticians — 2025

Mrs E Grisdale was employed by the Association of British Dispensing Opticians from 2 July 2007 until 31 October 2023, latterly doing work connected with the International Opticians’ Association and other international activity. The tribunal found that ABDO reviewed its international work in the context of financial pressure, including a forecast loss of £600,000 for 2023 and later an unexpected cyber attack costing around £100,000. In July 2023 the Board decided that ABDO would no longer continue to support the IOA beyond the end of 2023 and would curtail most international activities for the foreseeable future.

The tribunal held that this decision reduced the need for employees to do that work and therefore created a genuine redundancy situation. It found that the claimant was largely engaged on that work and that, out of around 30 employees, she was the only one doing it substantially, if not exclusively, for the whole of her working time. On that basis the tribunal rejected the argument that there should have been a selection pool, finding that this was not a selection case and that no other employee was in the same position.

On consultation, the tribunal found that the claimant had been involved in the review before the Board decision, was then warned that her role was at risk, and attended consultation meetings on 24 August, 10 October and 20 October 2023, each time accompanied by a colleague. It accepted that the respondent discussed her work and possible alternatives, and it rejected the submission that the process was only "lip service". The appeal was also found to have been properly considered, with Mr Gutsell hearing the appeal and the claimant's points discussed.

The tribunal also rejected the contention that the respondent should have created a new role for the claimant. It found there was no duty to create a post, and that it was within the range of reasonable responses not to offer her the later Project Manager role, which was a temporary post approved in February 2024 after her employment had ended. The tribunal concluded that the redundancy was genuine and that Mrs Grisdale was not unfairly dismissed, so the claim was dismissed.