Tribunal procedure: Settlement of unfair dismissal complaint did not bar unpaid wages claim

A compromise to settle an employee's claim for compensation for unfair dismissal, reached during the employment tribunal proceedings and recorded by the tribunal in a document headed "Decision of the [employment] tribunal", did not prevent the employee from subsequently bringing proceedings in the county court for unpaid wages, holds the Court of Appeal in Dattani v Trio Supermarkets Ltd [1998] IRLR 240. The tribunal's "decision" made no ruling on any disputed question, no declaration of rights and no order, and did not amount to a "decision" within the meaning of the employment tribunal Rules of Procedure.