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The First Decision Using the New Subdistrict Courts Formula

Dissolution to the Extent Required by Law

The decision of 30 January 2009 concerned a so-called dissolution to the extent required by law. The employee was summarily dismissed, but he declared this dismissal to be null and void. The employer requested the dissolution of the employment agreement in case the summary dismissal would not stand up in court. The Subdistrict Court deals with such a request as if it were a normal petition for dissolution and may therefore grant the employee compensation in that case too.

The Facts

A 38-year-old employee had been employed with Adomex as a truck driver for more than 17 years. Since February 2008 the employee had been warned a number of times in writing for, amongst other things, absence without leave, arriving late at work and situations of carelessness, including leaving a bag with money unattended. On 18 December 2008 the employee was summarily dismissed after leaving a bunch of keys with important keys for the company in the door of the truck on 17 December 2008 (the "key incident"). In the dismissal letter, reference was also made to the earlier warning letters about his behavior as a ground for the dismissal. Because the employee had declared the dismissal to be null and void, the employer requested the dissolution of the employment agreement to the extent required by law.

Subdistrict Court

The Subdistrict Court had to assess whether the employee's behavior constituted a serious reason on the basis of which the employment agreement could be dissolved. The Subdistrict Court primarily tests whether there is an urgent reason. The Subdistrict Court established that the employee had not received any written warnings during the first 15 years of his employment. Only two of the warnings he received since February 2008 related to the carelessness of the employee. In the opinion of the Subdistrict Court, the key incident in combination with the earlier warnings did not constitute an urgent reason now that during an employment of 17 years an act of carelessness was committed only twice, and without any intent. The Subdistrict Court ruled, however, that it was understandable that Adomex had lost confidence in the employee because he had failed in many ways. This constituted such a change of circumstances that the employment agreement had to end.

The Compensation

Since the petition was submitted after 1 January 2009, the Subdistrict Court has applied the new subdistrict courts formula for the calculation of the compensation. Next, the Subdistrict Court made a detailed written specification of the calculation. Rounded off, the employee had been in the employment for 17 years and 5 months on the date of the dissolution. The employee was born on 8 June 1970. For this reason 13 years (rounded off) fall within the category up to 35 years of age and 4 years (rounded off) fall within the category between 35 and 45 years of age. In view of the culpability on the part of the employee, the C factor was set at 0.5. The labor market position of the employee or the financial position of Adomex are not a reason to adjust the C factor and thus influence the compensation for dismissal. If the neutral formula would have been applied (C = 1) then the compensation is almost seven monthly salaries lower than it would have been on the basis of the old formula.

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Eva Knipschild

Tel: +31 20 5506 840
E-mail: eva.knipschild@kvdl.nl

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