Employment Law - Constructive Unfair Dismissal - Specific Complaint - Grievance

The case of Lambrou v Cyprus Airways Ltd [2007],The employer appealed.
concerned an employee who alleged that he wasAn issue arose as to whether the employee had
constructively unfairly dismissed. The employee wasfailed to present a grievance in respect of the
employed by Cypriar Tours Ltd ("Cypriar"), whichconstructive unfair dismissal as required by the
was a subsidiary of the employer. The employee wasEmployment Act 2002 (Dispute Resolution)
employed as a computer operator from the 23rd ofRegulations 2004.
January 1989. However, from the 1st of May 2003,The appeal would be allowed.
he also worked for the employer.It was held that dismissal claims were not subject to
In June 2004, all employees were given notice thatthe requirement that they went through a grievance
within the next three to four months Cypriar wouldunless they were for constructive dismissal. What
cease trading. The employee, who had not receivedwas required to be presented as a grievance was
his written terms of employment from the employer,the same complaint as the employee sought to have
requested a written contract.determined before the tribunal.
The employer's financial controller informed theIn this case, the very limited basis upon which the
accounts manager that the employee would beclaim had been allowed to go forward by the tribunal
transferred to its payroll from the 1st of October. Onhad been incorrect. The only basis on which the
the 27th of September, the employee sent an emailclaimant had got through the gateway to a hearing
to the general manager, seeking official clarification ofof his constructive unfair dismissal claim was reliance
his transfer. Subsequent to learning that his P45 hadupon the emails. The complaint sought to be
been issued for inter-company purposes, thedetermined before the tribunal was that the
employee requested a copy. His request was initiallyemployer had deemed the employee's contract not
refused, however, it was supplied to him on the 24thto be binding. In the earlier emails there had been
of September.mention of the dispute about the precise terms and
On the 30th of September, he sent an email to theconditions of employment. However, in those earlier
general manager and financial controller stating thatemails there had been no indication that the
he would be seeking legal advice on account of theemployee regarded his contract as void or that he
failure to clarify his terms of employment. After hewould take steps to leave. It followed therefore that
sent the e-mail, he did not return to work. Hethat was not the same complaint as was presented
brought proceedings in the employment tribunalto the tribunal and thus it had been wrong to allow
claiming constructive unfair dismissal. He alleged thatthat part of the case to go forward.
four matters had caused him to leave.If you require further information please contact us
The tribunal held that it had jurisdiction to determineat or Visit
only the claim which had formed in the employee's© RT COOPERS, 2007. This Briefing Note does
mind when he had decided to leave on the 30th ofnot provide a comprehensive or complete statement
September. This was the only claim in respect ofof the law relating to the issues discussed nor does it
which a grievance had been presented in the form ofconstitute legal advice. It is intended only to highlight
the emails, namely those based on his terms andgeneral issues. Specialist legal advice should always be
conditions of employment.sought in relation to particular circumstances.