Mrs S Quilty v Life Schools Ltd (in creditors voluntary liquidation) and Secretary of State for Department of Business and Trade — 2026

The Tribunal gave judgment under Rule 22 because the first respondent had not presented a response. The claimant claimed a protective award for breach of the collective consultation requirements under the Trade Union and Labour Relations (Consolidation) Act 1992. The first respondent was in liquidation and its liquidators had not responded; the second respondent, as an interested party, did not support or resist the claim.

The Tribunal found that the first respondent employed over 20 employees where the claimant worked and that no trade union was recognised for collective bargaining, consultation or negotiation at the site. Employees were told on 24 July 2024 that the first respondent was closing down and that they were all being made redundant with immediate effect.

The Tribunal found there was no proper warning or notice to, or consultation with, the workforce, and that no employee representatives had been elected or appointed for consultation within section 188A of the 1992 Act. It held that the first respondent was in breach of the duty under section 188 and that the claimant's complaint under section 189 was well-founded.

The Tribunal made a protective award under section 189 in favour of the claimant for the maximum protected period of 90 days beginning on 24 July 2024. It ordered the first respondent to pay the claimant a payment equivalent to remuneration for that period, subject to the Employment Protection recoupment provisions; no monetary figure was stated in the judgment.