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Expired Disciplinary Warnings

In the March 2006 issue of Employment Law SMIB, we reported the case of Diosynth Limited v Thomson. That case concerned the issue of whether an employer can have regard to an expired disciplinary warning when deciding upon the level of disciplinary sanction to impose on an employee. The EAT has now considered this issue again in Airbus UK Limited v Webb.

In July 2004, Mr Webb had received a final written warning for washing his car when he should have been working. The warning stated that it would remain on his personnel file for 12 months. Thereafter, some three weeks after expiry of the warning, Mr Webb and four of his colleagues were found watching television in a locker area. Again, this was at a time when they should have been working.

Disciplinary proceedings were instituted against all five employees. They were all found to have been guilty of gross misconduct but only Mr Webb was dismissed. The other four were given a final written warning and removed from night shift for a period. The employers justified the difference in treatment on the basis that, whilst Mr Webb had previously received a final written warning for similar misconduct, his four colleagues had clean disciplinary records. The circumstances of this case were accordingly very similar to the Diosynth case. In that case, the employers also sought to use a lapsed disciplinary warning as a basis for distinguishing between a number of employees who had committed the same misconduct.

The Employment Tribunal found Mr Webb to have been unfairly dismissed. The employers appealed to the EAT. Before the EAT, the employers' QC argued that the Diosynth case should not be followed and that it had been wrongly decided.

In the EAT's written judgement, the President of the EAT referred to the case raising "a difficult point where the arguments are finely balanced." Nonetheless, the EAT decided to follow the Diosynth case and, as a consequence, the employer's appeal was dismissed.

It follows therefore that once a disciplinary warning has expired, no weight at all can be attached to it in any subsequent disciplinary proceedings. This principle applies even when the misconduct that gave rise to the warning is exactly the same as the misconduct that is the subject of the subsequent proceedings. From a practical point of view, employers ought to consider the physical removal of lapsed warnings from personnel files as a protection against any suggestion that the warnings played a part in the disciplinary process.

As was highlighted in the Webb case, the ACAS Code indicates that final warnings should normally have a time limit of 12 months. If that rule of thumb is followed then an employee with the guile to wait 13 months between acts of misconduct would require to be treated as a first offender in each fresh set of disciplinary proceedings taken against him. From the employer's perspective, that cannot be right.

Fortunately, the EAT in Webb offers employers some guidance on this issue. It advises that warnings, and particularly final warnings, be tailored to the particular circumstances in which they are issued. If the misconduct justifies it, the 12 month time limit suggested by ACAS may need to be exceeded. Further, the EAT suggests that employers should consider extending the period of the warning with respect to a later act of gross misconduct which is the same or substantially the same as that for which the earlier warning was given. What is presumably envisaged by this latter piece of advice is that a final warning will state that it will lapse after 12 months other than where the employee is found guilty of misconduct of the same, or at least similar, nature as the earlier misconduct, in which case the 12 month period will be extended.

In offering employers this guidance, the EAT recognised that it is likely to lead to warnings becoming more complex but considered that, "if employers are going to be denied the right to have regard to expired warnings in any circumstances, then they must be allowed reasonable flexibility to formulate their rules to allow for exceptional cases."

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