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Bedford v. Pilgrims Group Ltd - Minor breach of contract and constructive unfair dismissal [2010] EAT

An employee cannot claim constructive dismissal (and thus constructive unfair dismissal) as a result of a minor breach by the employer of his employment contract (here the breach was a failure to pay 4 day's holiday pay after a TUPE transfer between employers who had different holiday years). 

Mr Bedford worked as a security officer for Shield Guarding Group at the site of a client: SunGard. The SunGard contract was later won by another security company, Pilgrims Group Ltd,  with the result that Mr Bedford's employment was automatically transferred to Pilgrims (under the TUPE regulations) in January 2008. Mr Bedford was later to claim that he was never happy with his employment at Pilgrims and indeed he informed Pilgrims that he was only signing an employment contract with them "under duress".

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