Langston v Cranfield University

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Langston v Cranfield University

  • Langston v Cranfield University, [1998] IRLR 172, EAT on 12th January 1998.
  • The full text judgment in this case is available free of charge on the BAILII website

Mr Langston was employed by Cranfield University as a research assistant under a series of fixed-term contracts. He was dismissed on grounds of redundancy in August 1995 when his final contract expired without being renewed. He claimed that his dismissal was unfair.

Mr Langston represented himself before the industrial tribunal, which isolated, as the sole question for determination, whether he was fairly selected for redundancy. The tribunal resolved that question in favour of the employer and dismissed the .

Case Summary

An example

of the factors an employment tribunal will take into account in deciding whether a redundancy dismissal was unfair.

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JUDGE PETER CLARK: The appellant before us in this case, Mr Langston, is by his own account something of an expert in explosives technology. We are not qualified to pass judgment on that claim. Equally, we think that he acknowledges that as an advocate, representing himself before the Industrial Tribunal and before us, he has much to learn. We can corroborate that. His appeal raises a question as to how far, if at all, Industrial Tribunals are under an obligation to enquire into matters inadequately raised by one or other or both of the parties in reaching their decision in redundancy dismissal cases. BackgroundThe appellant was continuously employed by the respondent under a series of fixed-term contracts as a research assistant from 1st May 1989 until expiry without renewal of his final contract on 31st August 1995. He was dismissed on that date by virtue of the provisions of s.95(1)(b) of the Employment Rights Act 1996. Following his dismissal he presented an Originating Application to the Industrial Tribunal dated 28th November 1995. He identified his complaint as “Unfair Dismissal – Harassment”. The matter came before an Industrial Tribunal sitting at Bristol on 26th February 1996. The decision of the tribunal, promulgated with extended reasons on 7th May 1996 reads as follows: “