Cases2305789/2024

Claimant v IMC Locums Ltd

10 November 2025Before Employment Judge M AspinallLondon Southremote video

Outcome

Other

Individual claims

Unlawful Deduction from Wagesnot determined

This preliminary hearing determined employment status only. The tribunal found the claimants were workers, giving jurisdiction to hear the claim. The substantive question of whether unauthorised deductions occurred (alleged underpayment from agreed £28/hour rate and non-payment of £200 bonus) will be determined at a final hearing.

Whistleblowingwithdrawn

Mr Kurian initially included a complaint of detriment following a protected disclosure (whistleblowing). This complaint was formally withdrawn by email on 31 July 2025 and dismissed upon withdrawal in a previous Case Management Order.

Facts

Two qualified audiologists were sourced by a healthcare recruitment agency (IMC Locums) to provide services at an NHS Trust. The agency maintained it merely introduced them to the Trust for direct engagement, while the Trust stated they were agency workers employed by IMC Locums. A dispute arose over pay rates - the claimants alleged they were promised £28/hour and a £200 bonus, but received lower amounts. The preliminary hearing addressed the fundamental question of who employed them.

Decision

The tribunal found the claimants were workers of IMC Locums Ltd, not employees of the NHS Trust. Applying Autoclenz, the judge disregarded misleading contractual labels and found that contemporaneous WhatsApp evidence from IMC's Divisional Lead showed the agency exercised control, negotiated rates, had a commercial margin, and acted as principal. The respondent's evidence was vague and unsupported. The tribunal has jurisdiction to hear the wage deduction claims at a final hearing.

Practical note

In agency worker cases, tribunals will prefer contemporaneous communications showing how arrangements actually operated over later witness evidence, and misleading contractual labels will not prevent worker status being found where the operational reality shows control and personal service.

Legal authorities cited

Ready Mixed Concrete v Minister of Pensions [1968] 2 QB 497Autoclenz Ltd v Belcher [2011] UKSC 41Uber BV v Aslam [2021] UKSC 5McMeechan v Secretary of State for Employment [1997] IRLR 353Levy McCallum Ltd v Middleton [2005] UKEAT 0020_05_0908

Statutes

ERA 1996 s.230(1)ERA 1996 s.230(3)(b)ERA 1996 s.13

Case details

Case number
2305789/2024
Decision date
10 November 2025
Hearing type
preliminary
Hearing days
1
Classification
contested

Respondent

Sector
healthcare
Represented
Yes
Rep type
lay rep

Employment details

Role
Audiologist

Claimant representation

Represented
No