The EAT in Wrexham Golf Club Co Ltd v Ingham has confirmed that the "range of reasonable responses" test applies to an employer's decision to opt for a "pool of one" in a redundancy exercise.
A golf Club's sole bar steward was made redundant as a cost-cutting exercise - bar duties were merged with catering. He successfully claimed unfair dismissal in the Employment Tribunal on the basis that the Club had not considered having a selection pool. The EAT sent the case back, saying that the Tribunal should have asked whether it was reasonable for the Club to consider only the one individual for redundancy, given that he was the Club's only bar steward, or whether it had to look at a wider range of employees.
This case appears to indicate that there can be situations where the employer acts reasonably even if the only issue considered is whether to dispense with a single role. Needless to say, however, it is advisable at least to consider whether to have a selection pool (and essential if there are other employees whose roles could be described as similar). Previous cases have established that if the employer has "genuinely applied his mind" to the issue of who should be in the pool, it will be difficult, although not impossible, for an employee to challenge it.