In Wrexham Golf Club Co Ltd v Ingham Mr
Ingham worked as the sole bar steward at a golf club. He was put at
risk of redundancy when the club decided to combine the bar and
catering operations. Mr Ingham's role would be performed by
other members of the catering staff. Mr Ingham alleged that he had
been unfairly dismissed, as the club had not considered the
possibility of establishing a selection pool but had decided from
the outset that Mr Ingham would be made redundant. He claimed that
the club had given no thought to the fact that there was a
considerable overlap between the work he did and that of other
The original tribunal held that the dismissal was unfair but the
EAT overturned this decision as it found that the tribunal had not
considered whether the decision to place Mr Ingham in a selection
pool of one was within the range of reasonable responses. The
tribunal should have asked itself whether, given the nature of the
steward's work, it was reasonable for the club not to consider
developing a wider pool of employees. In the EAT's view, there
will be cases where it is reasonable to focus on a single employee
without establishing a pool or even considering whether one should
be established. The EAT remitted the case for a fresh hearing.
Comment: This is a helpful case for employers
as it indicates that, in some straightforward redundancy
situations, where a decision is made to eliminate a single role, an
employer may act reasonably even if it does not apply its mind to
the question of establishing a selection pool. However, in most
cases it would still be prudent at least to consider whether a
selection pool is appropriate by considering whether the
employee's duties are broadly interchangeable with other
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