Smith v. American Life Insurance Company [2001] UKEAT 0280_00_1306 (13 June 2001)

Smith v. American Life Insurance Company [2001] UKEAT 0280_00_1306 (13 June 2001)

The disciplinary procedure was a contractual term and, once invoked, bound the employer to follow it fully. Dismissal during the procedure without completing all steps constituted breach of contract, entitling the employee to damages for the period the procedure would have taken, not just notice period.

Source-derived case information.

Citation
[2001] UKEAT 0280_00_1306
Parties
Appellant: A Smith; Respondent: Respondents
Jurisdiction
United Kingdom
Judgment Date
13 June 2001
Procedural Posture
Employment Tribunal Appeal / Appeal From Damages Assessment
Outcome
Appeal allowed; Tribunal's damages assessment substituted.
Legal Topics
Breach of Contract, Disciplinary Procedures, Notice Entitlement, Damages Assessment
Employment Law Contract Law Breach of Contract Disciplinary Procedures Notice Entitlement Damages Assessment

Source-derived case record

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Parties

A Smith

Appellant

Respondents

Respondent

Procedural Posture

Employment Tribunal Appeal / Appeal From Damages Assessment

  1. 1 Whether dismissal during disciplinary procedure breached contractual terms
  2. 2 Whether damages should be limited to notice period or include full disciplinary procedure duration

Ratio Decidendi

The disciplinary procedure was a contractual term and, once invoked, bound the employer to follow it fully. Dismissal during the procedure without completing all steps constituted breach of contract, entitling the employee to damages for the period the procedure would have taken, not just notice period.

Court Disposition

Appeal allowed; Tribunal's damages assessment substituted.

Orders

  • Respondents to pay additional compensation of £1,750 to Appellant.