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Case law
Mr P Western v Cheshire Curtainsiders Ltd

Your unfair dismissal award can still be cut for your own conduct, even after you win.

The ruling

Unfair dismissal upheld; award cut 25% for contributory conduct, raised 25% for ACAS Code breach.”

Winning an unfair dismissal claim doesn't guarantee full compensation if your own conduct played a part.

  • A tribunal can cut both your basic and compensatory award for contributory conduct, even after finding your dismissal unfair.
  • Contributory conduct works differently to a Polkey reduction. Your employer has to prove a Polkey argument with evidence; a tribunal can find contributory conduct without that.
  • Skipping a known disciplinary process makes a dismissal unfair almost automatically, however serious the conduct looks.
  • Failing to follow the ACAS Code of Practice can add up to 25% to your compensation, on top of any other adjustment.
Read the full case

The situation

A mobile trailer technician of five years' service was dismissed after his employer found serious problems with his works van. Warning lights were showing on the dashboard, tools had been left unsecured, and there was a petrol can stored near equipment that gets hot. There were also signs he had been smoking inside it.

The company director decided to sack him on the spot without asking him about any of it, and sent the termination letter by WhatsApp with photos attached.

What the tribunal found

The dismissal was unfair. The employer genuinely believed the conduct was serious, and it was, but it never investigated, never asked him to explain, and gave him no right of appeal, despite having a disciplinary procedure in his contract it had used before. The employer had followed none of the ACAS Code of Practice, so the tribunal added 25% to his compensation.

His employer argued he might have been dismissed anyway under a fair process, but put forward no evidence for that, so no reduction applied on that ground. The tribunal did, however, find that his own conduct had genuinely contributed to the dismissal. He admitted smoking in the van, and the tribunal accepted photographic evidence showing safety equipment left unsecured, rejecting his claim that the photos had been faked. The tribunal cut both his basic award and compensatory award by 25% as a result.

This is a useful contrast with a case where a Polkey reduction did apply, since the two adjustments work on entirely different grounds.

Full citation

Mr P Western v Cheshire Curtainsiders Ltd. Case No. 1307045/2024. Employment Tribunal (Birmingham). September 2025.

Last reviewed 16 July 2026