Royle v Greater Manchester Police Authority


Mrs Royle was a senior welfare officer at the police authority. She resigned in January 2004 and claimed that she had been constructively dismissed, citing various shortcomings of the authority that occurred between 1999 and 2004. Royle claimed they amounted to breaches of the implied term of trust and confidence and the authority’s duty to take reasonable care for her health and safety, and that there had been a fundamental breach of her contract of employment.

The tribunal considered that the authority’s conduct did not amount cumulatively to a fundamental breach of contract, and Royle’s claim was dismissed. She appealed, inter alia, on the ground that the tribunal had failed to make a finding on every allegation she had made.


The Employment Appeal Tribunal (EAT) dismissed the appeal. It held that where a claimant lists numerous complaints about their employer in a constructive dismissal case, the tribunal does not need to make a finding in relation to each complaint. In such a case, it is sufficient to make a finding as to whether there has been a fundamental breach of contract, taking into account all significant matters that are said to have contributed to that breach.


The EAT commented that it is preferable that a party who believes an important point has not been properly dealt with by the tribunal should seek clarification from the tribunal before seeking an appeal, given the expense and delay involved. Therefore, a party who wishes to complain that a tribunal has not dealt with all aspects of its case should consider raising the issue as soon as the reasons are received.

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