Damages are not limited to the term of the breached fixed term contract (but reflect the total loss caused)

Edwards v Chesterfield Royal Hospital NHS Foundation Trust [2010] EWCA Civ 571

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27/05/2010

Damages at large were awarded by the Court of Appeal in the case of Edwards v Chesterfield Royal Hospital NHS Foundation Trust [2010] EWCA Civ 571.

It was decided that a doctor whose contract was subject to 3 months' notice could recover damages resulting from a breach of his contractual disciplinary procedure which resulted in his dismissal for misconduct loss of professional status.

The hospital argued that (according to Gunton v Richmond-upon-Thames LBC [1980] ICR 755) any damages awarded should only cover the contractual period of notice and any period needed for contractual disciplinary procedures to be completed to have been carried out. The Court of Appeal rejected this argument as:

  • The Gunton v Richmond-upon-Thames decision did not support the employer as that decision could be explained, "only on the basis that the employee had a contractual right to have the benefit of the agreed disciplinary procedure before he was dismissed" (s26 & s40).

  • Normal contractual remedies follow a breach of the express term relied on by an employee. An injunction could have been awarded, had it been applied for in time.
  • Johnson v Unisys and the Employment Rights Act 1996 did not take away contractual or common law rights.
  • Following Lord Steyn's decision in Skidmore v Dartford and Gravesham NHS Trust, disciplinary procedures should be followed and "comply with the terms of the contract. If a non-conforming decision is taken and acted upon, there is a breach of contract resulting in the usual remedies"(s15).
  • The reasons given by Slade J in sections 42 and53 in Botham v Ministry of Defence were wrong .

Permission to appeal to the Supreme Court is being sought by the employer.

The transcript of this case follows:-  

Edwards v Chesterfield Royal Hospital NHS Foundation Trust [2010] EWCA Civ 571



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