Case 6021196/2024 · Employment Tribunal
Karl Dorman v Reed Talent Solutions Limited and 1 other — 2026
- Case reference
- 6021196/2024
- Decision date
- 17 August 2026
- Jurisdiction
- England & Wales
- Judge
- Employment Judge N Wilson Appearances
Parties
3 namedClaimant
Karl Dorman
Key findings
Tribunal's reasoningThe tribunal dismissed Karl Dorman's ordinary unfair dismissal, automatic unfair dismissal and protected disclosure detriment complaints against Reed Talent Solutions Limited and London Fire Commissioner. Dorman accepted that he did not have two years' qualifying service, so the tribunal had no jurisdiction to hear ordinary unfair dismissal. It did not decide whether he was an employee because that question was unnecessary to the jurisdictional decisions.
Dorman's assignment ended on 3 April 2024. The tribunal found that all claims as presented arose from acts on or before that date. ACAS early conciliation ran from 4 to 5 December 2024, and the ET1 was presented on 7 December 2024. Reed communicated the termination on 3 April, and an email from London Fire Commissioner on 8 April gave further reasons and confirmed that the placement had ended with no return to the role. The tribunal distinguished this from his volunteering, which had been paused pending investigation.
The tribunal found that Dorman sought legal advice immediately after termination and contacted ACAS shortly afterwards. It found that he knew time limits applied before the initial limitation period expired. His explanation for waiting was that he was trying to resolve matters internally. He gave no evidence that he had been advised to delay proceedings or was otherwise prevented from bringing them. Applying the reasonable practicability test, the tribunal refused an extension and dismissed the protected disclosure complaints as out of time.
The tribunal also found that the disclosures Dorman relied on followed the termination of his assignment. These included an oral disclosure at the end of April 2024 and an email on 8 May 2024. His attempt to rely on a colleague's disclosure to him and her subsequent complaint about him did not fit the statutory framework. The tribunal found that the later detriments he raised at the hearing, concerning emails in November 2024, were not pleaded in his ET1. It stated that, had the whistleblowing complaint survived the time limit decision, it would have been struck out for having no reasonable prospect of success because of the claimant's own chronology.
Dorman also described a sex discrimination complaint concerning the different treatment of his complaints and those made by a female colleague. The tribunal found that this complaint was neither expressly pleaded nor reasonably inferable from the ET1. No amendment application was before it, and no claim survived to support an amendment. The judgment recorded that sexual harassment and victimisation complaints had previously been withdrawn and dismissed. No complaints remained, the proceedings ended, and no monetary remedy was awarded.
Claims and outcomes
3 findings recorded| Claim type | Issue or finding | Outcome | Protected characteristic | Award |
|---|---|---|---|---|
| Unfair dismissal | Ordinary unfair dismissal under section 94 ERA 1996 was dismissed against both respondents because the claimant lacked the required two years' qualifying service. Employment status was not determined. | Dismissed | — | — |
| Unfair dismissal | Automatic unfair dismissal for protected disclosures under section 103A ERA 1996 was dismissed against both respondents as out of time. The tribunal found it was reasonably practicable to present the complaint within time. | Dismissed | — | — |
| Whistleblowing | Protected disclosure detriment under section 47B ERA 1996 was dismissed against both respondents as out of time. The tribunal's further observation that the complaint would have been struck out for having no reasonable prospect of success was an alternative conclusion, not the operative disposal. | Dismissed | — | — |
Legal tests applied
8 references- Two years' qualifying service for ordinary unfair dismissal under section 94 ERA 1996
- Section 111(2)(a) ERA 1996: three-month time limit for unfair dismissal
- Section 48 ERA 1996: time limit for detriment complaints
- Reasonably practicable test for extending time
- Palmer and anor v Southend-on-Sea Borough Council [1984] ICR 372
- Asda Stores Ltd v Kauser EAT 0165/07
- Lowri Beck Services Ltd v Brophy [2019] EWCA Civ 2490
- Rule 38(1), Employment Tribunal Rules of Procedure 2024: no reasonable prospect of success (alternative conclusion)
Official outcome judgment PDF
Gov.uk primary recordThe 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.
Published on gov.uk under the Open Government Licence v3.0.
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