← Back to case studies
Case law
Polkey v AE Dayton Services Ltd

Being made redundant without any process is still unfair dismissal.

The ruling

“Dismissal found unfair. Employer could not rely on inevitability of outcome to excuse procedural failure.”

If you were made redundant without warning or consultation, you were denied something you were legally entitled to. A genuine redundancy situation does not make an unfair process acceptable.

  • You were entitled to be told you were at risk before a decision was made, and to a genuine opportunity to raise questions or suggest alternatives. Skipping those steps is unfair dismissal, regardless of whether the underlying business decision was sound.
  • Even where a tribunal finds procedural unfairness, it may reduce any compensation award to reflect the likelihood the outcome would have been the same. But that is a separate question from whether what happened to you was fair.
  • Time limits for unfair dismissal claims are strict. If you were recently dismissed without any process, take advice as soon as possible.
Read the full case

The situation

A van driver was called into his manager's office and told, without any warning, that he was being made redundant. There was no prior conversation, no consultation, and no procedure of any kind. The redundancy itself was genuine. The business needed to reduce its workforce and his role was going. The employer's position, when challenged, was that a proper process would not have changed anything, so the absence of one was irrelevant.

What the tribunal found

The House of Lords disagreed. In Polkey v AE Dayton Services Ltd [1987] IRLR 503, the court held that an employer cannot argue its way out of a procedural failure by pointing to the inevitability of the outcome. The dismissal was unfair because the process was unfair. The question of whether following a proper procedure would have made any difference is a compensation question, not a fairness question. Those are two separate assessments.

Full citation

Polkey v AE Dayton Services Ltd. [1987] IRLR 503. House of Lords. 19 November 1987.

Last reviewed 26 June 2026