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Kaltz Ltd v Hamer - Rejection of "ordinary" unfair dismissal claim does not preclude finding of automatically unfair dismissal [2011] EAT

An employment tribunal is entitled, on appropriate evidence, to rule that a dismissal was not "ordinarily unfair", but nonetheless was "automatically unfair" because the principal reason for dismissal was the making of a protected disclosure.

Ms Hamer was dismissed from her job as an administrator, due to a heated argument with her managers and disclosing confidential payroll information. She brought a number of claims before an employment tribunal. Her claims of breach of contract, sex discrimination, and "ordinary" unfair dismissal all failed.

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