Cases6022907/2025

Claimant v Newsteam Group Ltd.

5 November 2025Before Employment Judge S ShoreEast London Hearing Centreremote video

Outcome

Claimant fails

Individual claims

Unfair Dismissalfailed

The tribunal found the claimant was not an employee under section 230 of the Employment Rights Act 1996. He was a self-employed contractor with an unfettered right to substitute under the Independent Contractor Agreement. Without employee status, the tribunal had no jurisdiction to hear an unfair dismissal claim.

Breach of Contractfailed

The claimant sought £120 for a replacement tyre damaged during delivery work. The claim failed because the tribunal found the claimant was neither an employee nor a worker as defined in section 230 ERA 1996, so the Employment Tribunal Extension of Jurisdiction Order 1994 did not apply.

Unlawful Deduction from Wagesfailed

The claimant claimed £40 for his shift on 27 March 2025 and £150 for lost earnings. The tribunal found the claimant was not a worker or employee under section 230 ERA 1996, therefore section 13 ERA 1996 (protection against unauthorised deductions) did not apply. The respondent had invoked a contractual deductions clause in the Independent Contractor Agreement.

Facts

The claimant worked one shift as a newspaper delivery driver on 27 March 2025 for £40. He signed an Independent Contractor Agreement without reading it, which specified he was self-employed with an unfettered right to substitute. During the shift, his car hit a pothole and punctured a tyre. Unable to work the next shift due to the tyre damage, he was locked out of the company app and told to reapply. The respondent did not pay him for his completed shift, invoking a contractual deductions clause. The claimant claimed £40 in unpaid wages, £120 for the replacement tyre, and unfair dismissal.

Decision

The tribunal dismissed all claims on jurisdictional grounds. It found the claimant was a self-employed contractor, not an employee or worker under section 230 ERA 1996. The written Independent Contractor Agreement contained a genuine and unfettered right to substitute, which was inconsistent with the obligation for personal performance required for worker status. Without employee or worker status, the tribunal had no jurisdiction to hear claims for unfair dismissal, breach of contract, or unlawful deduction of wages.

Practical note

A genuine and unfettered contractual right to substitute is fatal to worker status claims, even where the individual worked only one shift and did not actually use the substitution clause.

Legal authorities cited

Uber BV v Aslam [2021] UKSC 5Bates van Winkelhof v Clyde & Co LLP [2014] UKSC 32Pimlico Plumbers Ltd v Smith [2018] UKSC 29Clark v Oxfordshire Health Authority [1998] IRLR 125 CATer-Berg v Simply Smile Manor House Ltd [2023] EAT 2Autoclenz Ltd v Belcher [2011] UKSC 41Ready Mixed Concrete v Minister of Pensions [1968] 2 QB 497

Statutes

ERA 1996 s.230ERA 1996 s.13Employment Tribunals Extension of Jurisdiction (England & Wales) Order 1994 Article 3ERA 1996 s.27ERA 1996 s.94ERA 1996 s.95(1)(c)ERA 1996 s.98ERA 1996 s.108

Case details

Case number
6022907/2025
Decision date
5 November 2025
Hearing type
full merits
Hearing days
1
Classification
contested

Respondent

Sector
media
Represented
No
Rep type
in house

Employment details

Role
Newspaper and magazine delivery driver

Claimant representation

Represented
No