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Faithorn Farrell Timms LLP v Bailey

Pre-termination settlement talks cannot normally be used against you in tribunal.

The ruling

“Pre-termination settlement talks are protected in an ordinary unfair dismissal claim, but the shield does not cover discrimination, whistleblowing, breach of contract, or improper pressure.”

Pre-termination settlement conversations are protected from use in ordinary unfair dismissal proceedings under section 111A of the Employment Rights Act 1996, but the protection does not cover breach of contract, discrimination, whistleblowing, or automatic unfair dismissal claims.

  • If you also have a breach of contract, discrimination, or whistleblowing claim, what was said in a 'protected conversation' may still be usable against your employer in those claims, even though it is shielded in an ordinary unfair dismissal claim.
  • If your employer behaved improperly during a protected conversation, for example through undue pressure or threats, the protection falls away and what happened can be used in evidence.
  • Take advice before engaging in a protected conversation so you understand what it covers and what claims you may have that fall outside it.
Read the full case

The situation

Section 111A of the Employment Rights Act 1996 introduced a separate statutory protection for pre-termination negotiations: conversations between employer and employee about ending employment on agreed terms, known as protected conversations. The question in this case was how that protection works alongside the common law without prejudice rule, and what is protected under section 111A.

What the tribunal found

The Employment Appeal Tribunal held that the section 111A protection applies to any offer made or discussions held before termination with a view to reaching a settlement agreement, in a situation where there is no existing dispute. Unlike the common law without prejudice rule, section 111A does not require a dispute to be in existence at the time of the communication. It applies to pre-emptive settlement conversations, including the initial approach.

The tribunal also confirmed that section 111A protection applies to the fact of the conversation and its contents in ordinary unfair dismissal proceedings. But the protection is narrow. It does not extend to breach of contract claims, discrimination claims, whistleblowing claims, or other statutory rights beyond ordinary unfair dismissal. In this case, the tribunal specifically held that section 111A did not apply to the employee's breach of contract claim.

Full citation

Faithorn Farrell Timms LLP v Bailey | [2016] UKEAT/0025/16/RN | Employment Appeal Tribunal | 28 June 2016

Last reviewed 4 July 2026