Case 2502524/2022 · Employment Tribunal

Miss J Graham v Short Richardson and Forth Limited In Voluntary Liquidation — 2023

Case reference: 2502524/2022
Decision date: 4 July 2023
Jurisdiction: England & Wales
Judge: Employment Judge Arullendran Date

Indexed: 19 May 2026

Parties

2 named

Claimant

Miss J Graham

Respondent

Short Richardson and Forth Limited In Voluntary Liquidation

Key findings

Tribunal's reasoning

The tribunal found the claimant's section 189 claim well founded. The respondent proposed to dismiss 20 or more employees for redundancy at its Newcastle office, with the first dismissal taking effect on 30 September 2022 and the last on 30 November 2022.

The tribunal found there was no proper warning or consultation with a recognised trade union or with the claimant, and no employee representatives had been elected or appointed for consultation within section 188A. On that basis, the respondent was in breach of its duty under section 188 of the 1992 Act.

The tribunal therefore made a protective award for the maximum protected period of 90 days beginning on 30 September 2022. It also held that the recoupment regulations applied to the protective award. No award was made for pension contributions because that issue was being dealt with by Clumber Consultancy.

Claims and outcomes

1 finding recorded

Claim type	Issue or finding	Outcome	Protected characteristic	Award
Other	Protective award claim under section 189 of the Trade Union and Labour Relations (Consolidation) Act 1992 for failure to comply with section 188 collective consultation requirements. The judgment awards 90 days' remuneration from 30 September 2022 but does not state a monetary figure.	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

Published on gov.uk under the Open Government Licence v3.0.

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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