Respondent won Employment Tribunal · 24 February 2023

Security officer dismissed for sleeping on duty: employer's decision upheld

A security officer with 11 years' service was fairly dismissed after video evidence showed her apparently sleeping on duty. The tribunal upheld G4S's decision, finding the employer acted reasonably.

1 min read · Last updated 18 May 2026

Case details

Key facts

  • The claimant was employed as a security officer from 4 August 2008 until dismissal on 23 January 2020.
  • The respondent dismissed the claimant for gross misconduct after a video showed her with eyes closed and motionless while on duty.
  • The claimant had a previous final written warning for assaulting a team leader.
  • The respondent conducted an investigation, disciplinary hearing, and appeal before dismissing the claimant.
  • The tribunal found the respondent had a genuine belief in the claimant's misconduct and acted reasonably.

Timeline

  1. Employment started

    Claimant began working as a security officer for G4S.

  2. Placement at Barking JCP

    Claimant worked at DWP Barking premises from about January to September 2019.

  3. Assault allegation

    Allegation that claimant assaulted team leader Shabbir Ahmed; she was suspended.

  4. Disciplinary hearing for assault

    Hearing held by Mr Islam; claimant issued final written warning on 18 October 2019.

  5. Video received by respondent

    Mr Islam received an email from Mr Baig attaching a video showing claimant apparently sleeping on duty.

  6. Investigatory interview

    Mr Shemar interviewed claimant; she denied sleeping and challenged the video.

  7. Disciplinary hearing and dismissal

    Mr Islam held disciplinary hearing and summarily dismissed claimant for gross misconduct (sleeping on duty).

  8. First appeal hearing (claimant absent)

    Claimant did not attend; no communication received.

  9. Second appeal hearing (claimant absent)

    Claimant again did not attend; appeal dismissed in her absence.

  10. Appeal outcome letter

    Mr Gregoriades wrote to claimant dismissing her appeal.

The outcome

The tribunal dismissed both the unfair dismissal and wrongful dismissal claims. It found that G4S had a genuine belief in the misconduct based on the video, conducted a reasonable investigation, and followed a fair procedure including an appeal. The claimant's previous final written warning for assault was a relevant factor in the decision to dismiss.

Lessons & takeaways

  • Video evidence can be powerful; employers should ensure it is properly obtained and reviewed before relying on it.
  • A previous final written warning can make dismissal for a further misconduct more likely to be fair.
  • Employers should follow a full disciplinary process, including investigation, hearing, and appeal, to reduce the risk of an unfair dismissal finding.
  • Employees should be aware that sleeping on duty, especially in a security role, is likely to be treated as gross misconduct.

When video evidence leads to dismissal

This case shows how a single piece of video evidence can be enough to justify a gross misconduct dismissal, even for a long-serving employee. The security officer had worked for G4S for over 11 years, but a video showing her with eyes closed and motionless while on duty led to her summary dismissal.

What the employer did right

G4S conducted a thorough process: an investigation, a disciplinary hearing, and an appeal. The decision-maker had a genuine belief in the misconduct based on the video, and the tribunal found this belief was reasonable. The claimant's previous final written warning for assaulting a team leader also played a role, as it meant she was already on a final warning.

Why the result matters

For employees in safety-critical roles like security, sleeping on duty is almost certain to be treated as gross misconduct. Even with long service, the employer's response was within the range of reasonable responses. The tribunal emphasised that it is not for them to substitute their own view for the employer's, as long as the employer acted reasonably. This case reinforces that employers can rely on clear evidence and a fair process to defend dismissal decisions.

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