And speaking of explosive reactions brings me to the case of Bell v Carpenters LTD 2025 and whether an angry employee was genuinely forced to resign.

Miss Bell was employed as a solicitor for Carpenters Ltd in August 2005. She was later promoted to Legal Training Manager in late 2016, overseeing trainee solicitors until she resigned in September 2023.

Prior to the pandemic, there had been a strained relationship between Miss Bell and her line manager, Mr Norbury. She exhibited inappropriate behaviour and language over emails regarding pay grades for her position, and Mr Norbury’s management decisions.

There were also issues regarding Miss Bell’s own line management responsibilities. She had been unsympathetic towards a team member who wanted time off to attend quite serious medical appointments. When confronted about this by Mr Norbury, she said some unpleasant things about this team member and subsequently the matter had to be handled by another manager.

In October 2019, Mr Norbury began a Performance Assessment Process (PAP) for Miss Bell, to review the issues that had arisen, including the inappropriate behaviour and communication. In the months following this, Mr Norbury deemed Miss Bell’s performance to have improved enough to resolve the PAP.

Carpenters Ltd was significantly affected by the 2020 pandemic and the whole training team, including Miss Bell, was furloughed until July 2021. Upon her return to work, Miss Bell found that she had been relieved of her management duties without any formal consultation or offer of alternative responsibilities. Miss Bell expressed her concerns at losing part of her job responsibilities and felt vulnerable to cuts during the recovery period following the pandemic. When informed that it was partly a legitimate business need and partly due to Miss Bell’s management style, she reacted confrontationally.

In August 2023, Miss Bell was invited to a Teams meeting with Mr Norbury where she requested extra resources. When asked to demonstrate her performance outputs, Miss Bell reacted badly, believing her work was being challenged and walked out of the meeting stating that she would resign. That same day, Miss Bell formally resigned, stating that she felt punished for raising workplace issues and Mr Norbury “picking holes” in her performance.

Miss Bell then filed a claim for unfair dismissal to the Employment Tribunal.

The claim was unsuccessful. The ET found that although Miss Bell’s role had been reduced following the pandemic and internal restructuring, Carpenters LTD’s actions, such as the changes in responsibilities and managerial oversight, were reasonable responses to business needs and did not amount to a breach of contract or trust. Miss Bell’s resignation was found to be her personal choice rather than the result of unfair or coercive treatment by Carpenters LTD. As such, the ET concluded that she had voluntarily resigned and had not been constructively dismissed.

This case should come as a reminder for employers of the importance of clear communication, fair performance management, and transparent restructuring processes. While Carpenters LTD ultimately succeeded in defending the claim, the case highlights how perceived unfair treatment, such as changes to job roles without formal consultation or strained management relationships, can escalate into legal action.

Employers should be sure to document all performance concerns, follow fair procedures (especially during organisational changes), and ensure that employees are consulted and supported during transitions. Doing so not only mitigates legal risk but also fosters a more trusting and resilient workplace culture.