The tribunal must not elaborate when answering questions put by the EAT (Burns-Barke procedure)
WOODHOUSE SCHOOL v WEBSTER - [2009] EWCA Civ 91

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  • The limits of the Burns-Barke procedure have been defined by the Court of Appeal (CA). When the EAT asks the ET to clarify decisions (where these were inadequate or where no reasons at all were given), the ET must not supply additional information or reasons in defence of its decision.
  • The ET was justified in widening the scope of a complaint made in the ET1; the ET could consider and then make a finding of constructive dismissal even where an implicit instruction of an employer to dismiss was not listed in the ET1 (the complaint alleged that the employer gave the claimant an explicit instruction by to dismiss a disabled worker)

Mr Webster was in charge of Woodhouse school for severely disturbed girls whilst the owner Pat Moore was ill with cancer. Whilst Mr Moore was away Mr Webster hired a profoundly deaf teacher who performed her job satisfactorily. Mr Moore however wanted her dismissed before her 6 month fixed contract ended. Mr webster said he was directly instructed to dismiss the teacher, whereas the ET believed that he was given to understand this in an indirect manner. After listening to a tape recording of a meeting between Webster and Moore where Moore talked about his intention to dismiss the disabled teacher, the Court of Appeal upheld the tribunal's finding that the instruction to dismiss was on a 'nod and a wink' basis.

An unfair dismissal claim was brought against the school contending that the instruction to terminate the teacher’s employment because of her disability was unlawful and a breach of the contractually implied term of mutual trust and confidence. On the evidence before the tribunal, the majority found that, while at no point had Mr Moore expressly instructed the claimant to dismiss the teacher, the meaning of his words was as interpreted by the claimant.

The Court of Appeal found that when a tribunal based findings on the evidence and gave the parties a fair opportunity to explain their positions regarding the substance of evidence before it, there could be no valid case made for complaints of injustice or procedural unfairness.

The claim of constructive unfair dismissal was upheld. The school’s appeal to the Employment Appeal Tribunal was dismissed. As to whether the claimant's evidence was undermined in that the tribunal did not believe he had been expressly instructed to dismiss, but rather intimated in an indirect manner so to do, the CA decided that oral evidence did not need to be perfect. The tribunal was allowed to decide on the balance of probabilities, that the claimant’s testimony was reliable enough to make a decision as to whether he had been instructed to dismiss the teacher.

The CA dismissed the appeal upholding the finding of constructive dismissal against the claimant.

The transcript of the decision in this case can be found: here


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