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Case law
Abernethy v Mott, Hay and Anderson

The real reason for your dismissal must match the stated reason.

The ruling

“Court of Appeal upheld dismissal, holding the real reason was capability, not the stated redundancy label.”

An employer can correct the label it gives your dismissal, but only if the real facts behind it were already known at the time. A reason that surfaces for the first time at tribunal is a different matter.

  • Keep a timeline of what your employer said and when, from your dismissal through any appeal and into tribunal proceedings.
  • If the stated reason shifts after you raised a grievance, made a protected disclosure, or exercised a statutory right, treat that shift as evidence worth preserving.
  • Get advice early if you think the real reason is one your employer would rather not admit to.
Read the full case

The situation

A civil engineer had worked for the same employer for 20 years. When the business reorganised, he was asked to take a secondment elsewhere and turned it down. His employer then dismissed him and gave the reason as redundancy, paying him a redundancy payment plus an additional ex gratia sum.

What the court found

The tribunal did not accept that this was a genuine redundancy. It found the true reason was different: the employee lacked the flexibility and adaptability the role now required, which was a capability issue rather than a reduction in the employer's need for the work. The Court of Appeal upheld this and set out the test still used today. Lord Denning MR held that an employer does not have to get the label right at the time of dismissal, provided the facts behind the real reason were already known, or made known, to the employee. Cairns LJ went further: the reason for a dismissal is the set of facts the employer actually knew, or the beliefs it actually held, that caused it to dismiss. A reason given at the time is evidence of what that was, but it is not the last word on it.

Full citation

Abernethy v Mott, Hay and Anderson. [1974] ICR 323. Court of Appeal. 6 February 1974.

Last reviewed 4 July 2026