Mackay v. Hanna (t/a Blakes Newsagents) [2007] UKEAT 0181_07_1105 (11 May 2007)

Mackay v. Hanna (t/a Blakes Newsagents) [2007] UKEAT 0181_07_1105 (11 May 2007)

A claim for unfair dismissal on grounds of age discrimination does not require prior submission of a grievance under S32(2) Employment Act 2002 if the discrimination is not a freestanding complaint but relates to the dismissal itself.

Citation
[2007] UKEAT 0181_07_1105
Parties
Appellant: Appellant; Respondent: Respondent
Jurisdiction
United Kingdom
Judgment Date
11 May 2007
Procedural Posture
Employment Appeal / Full Hearing of Appeal From Employment Tribunal Decision
Outcome
Appeal allowed in part
Legal Topics
Age Discrimination, Unfair Dismissal, Grievance Procedure, Holiday Pay, Part Time Working Regulations

Case Brief

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Parties

Appellant

Appellant

Respondent

Respondent

Procedural Posture

Employment Appeal / Full Hearing of Appeal From Employment Tribunal Decision

  1. 1 Whether a grievance is required for a claim of unfair dismissal on grounds of age discrimination under S32(2) Employment Act 2002
  2. 2 Whether a claim for unpaid holiday pay requires a prior grievance submission

Ratio Decidendi

A claim for unfair dismissal on grounds of age discrimination does not require prior submission of a grievance under S32(2) Employment Act 2002 if the discrimination is not a freestanding complaint but relates to the dismissal itself.

Court Disposition

Appeal allowed in part

Orders

  • Claim for unfair dismissal on grounds of age discrimination allowed to proceed without prior grievance.
  • Claim for unpaid holiday pay requires a grievance and was properly rejected as premature.