Une sanction n’est légitime que si elle est prévue par le règlement intérieur
La sanction disciplinaire est définie par l’article L.1331-1 du code du Travail comme étant toute mesure, autre que les observations verbales, prise par l’employeur à la suite d’un agissement du salarié considéré par l’employeur comme fautif, que cette mesure soit de nature à affecter immédiatement ou non la présence du salarié dans l’entreprise, sa fonction, sa carrière ou sa rémunération.
Dans un arrêt du 23 mars 2017, la Cour de cassation a confirmé qu’une sanction non prévue par le règlement intérieur est illicite.
Pendant longtemps, la Chambre sociale estimait que le pouvoir disciplinaire était inhérent à la qualité d’employeur.
Mais depuis 2010, la Cour de cassation applique strictement les dispositions du Code du travail sur ce sujet. En effet, elle a jugé qu’étant donné que le règlement intérieur fixait les règles de l’entreprise relatives à la discipline, notamment la nature et l’échelle des sanctions qui peuvent être prononcées par l’employeur, une sanction ne peut être prononcée que si elle figure dans ce règlement (Cass. Soc., 26 oct. 2010, n° 09.42-740).
Cette solution, régulièrement confirmée, l’est à nouveau dans l’arrêt du 23 mars 2017.
L’arrêt dans son intégralité : Cass. Soc., 23 mars 2017, n° 15-23.090
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