Decision date
12 January 2026
Tribunal
Employment Appeal Tribunal
Jurisdiction
England & Wales
Judge
His Honour Judge James Tayler
Case Summary
This appeal concerns the requirements of a fair procedure where misconduct is alleged, including natural justice, ACAS guidance and the fundamental statutory test. On the facts of this case the Employment Tribunal was not required to find that a dismissal was unfair due to certain issues with the investigation and disciplinary process.
Why this outcome?
Dismissal found fairThe tribunal found that despite procedural issues in the investigation and disciplinary process (such as the investigator and note taker providing witness statements, late disclosure of evidence, and potential bias comments), these defects did not render the dismissal unfair on the facts of this case.
Claim Types
Key Issues
- •requirements of a fair procedure where misconduct is alleged, including natural justice, ACAS guidance and the fundamental statutory test
Decision Text
Judgment approved by the court for handing down Lamb v Teva UK Ltd © EAT 2026 Page 1 [2026] EAT 8 Neutral Citation Number: [2026] EAT 8 Case No: EA-2023-000610-AS EMPLOYMENT APPEAL TRIBUNAL Rolls Building Fetter Lane, London, EC4A 1NL Date: 12 January 2026 Before : HIS HONOUR JUDGE JAMES TAYLER - - - - - - - - - - - - - - - - - - - - - Between : CRAIG LAMB Appellant - and – TEVA UK LTD Respondent - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - Hana Abas (acting as a FRU representative) for the Appellant Mark Humphreys (instructed by Travers Smith LLP) for the Respondent Hearing date: 2 December 2025 - - - - - - - - - - - - - - - - - - - - - JUDGMENT Judgment approved by the court for handing down Lamb v Teva UK Ltd © EAT 2026 Page 2 [2026] EAT 8 SUMMARY Unfair Dismissal This appeal concerns the requirements of a fair procedure where misconduct is alleged, including natural justice, ACAS guidance and the fundamental statutory test. On the facts of this case the Employment Tribunal was not required to find that a dismissal was unfair because (1) the person who conducted the investigation provided a witness statement as part of the investigation (2) the note taker in the investigation also provided a witness statement as part of the investigation (3) evidence that was said to have materially increased the seriousness of the allegation was provided less than 24 hours before the disciplinary hearing; and/or (4) it was possible that the person who conducted the investigation had been overheard saying that “I don’t think he is going to be back at the business” or he “is done at the business”. Judgment approved by the court for handing down Lamb v Teva UK Ltd © EAT 2026 Page 3 [2026] EAT 8 HIS HONOUR JUDGE JAMES TAYLER The issue 1. The issue in this appeal is whether an Employment Tribunal was required to fi…
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Case Details
- Claimant
- Mr Craig Lamb
- Case No.
- [2026] EAT 8
- Appeal
- Appeal outcome unclear
- Tribunal
- Employment Appeal Tribunal
- Level
- Appeal
- Decision
- 12 January 2026
- Published
- 12 January 2026
- Jurisdiction
- England & Wales
- Judge
- His Honour Judge James Tayler