Employment Law - Unfair Dismissal and Constructive Dismissal - 'Last Straw' Principle

An employee who had been employed since 1997However, the employer appealed to the Employment
tried unsuccessfully to claim that she had beenAppeal Tribunal. The main issue considered in the
unfairly and constructively dismissed in the case ofappeal was whether or not the tribunal had erred in
Hughes v Gibson and Others (trading as Blanfordconcluding that the letter of 29 October was the final
House Surgery) [2006].act required to bring into effect the 'last straw'
In early June 2004, a number of comments wereprinciple, even though she had reaffirmed her
made in the presence of the employee that led heremployment contract when she withdrew her
to indicate to her employer her intention to resignresignation on the 28 June.
from her position. On 4 June 2004, the employee'sThe appeal was allowed due to the fact that in order
practice manager informed her in writing that herfor the 'last straw' principle to be applied, there has
resignation was not accepted. Subsequently, on 28to be more than one act which is capable of being
June, she withdrew her resignation.complained of. The severity of the acts complained
She filed a grievance against her employer and on 29of is not that important, as long as cumulatively they
October she received a letter from managementamount to a breach of contract.
regarding her complaints. The letter acknowledgedBecause the employee had reaffirmed her contract
some of her complaints, informed her that some ofwhen she withdrew her resignation, the tribunal had
her complaints could not be made out, and told herbeen incorrect to apply the 'last straw' principle. The
that there would be a meeting the following week inretraction of her resignation had prevented any of
which the issues highlighted in her grievance could bethe acts prior to 28 June being considered, which left
further discussed.only one act which was capable of being complained
Shortly after the receipt of the letter, she informedof - the letter of 29 October. Therefore there was
management of her intent to seek a hearing beforeonly one act in the series of events required for the
an employment tribunal. On 29 November, she'last straw' principle, meaning it could not be applied
resigned from her position, claiming that she had beenhere. It was held that the letter on its own did not
unfairly and constructively dismissed. The tribunal heldamount to unfair or constructive dismissal.
that the letter of 29 October had not handled theIf you require further information please contact us
employee's grievance appropriately. The tribunal ruledat or Visit
that:-© RT COOPERS, 2007. This Briefing Note does
§ the letter had been part of a series of eventsnot provide a comprehensive or complete statement
§ there had been a breakdown in trust andof the law relating to the issues discussed nor does it
confidence between the employee and the employerconstitute legal advice. It is intended only to highlight
§ the employee had in fact been unfairly andgeneral issues. Specialist legal advice should always be
constructively dismissed.sought in relation to particular circumstances.