Cases6018986/2024

Claimant v Debrett's Education Limited

30 October 2025Before Employment Judge BurgeLondon Southremote video

Outcome

Claimant fails

Individual claims

Wrongful Dismissalstruck out

The tribunal concluded that the Employment Tribunal of England and Wales did not have jurisdiction to hear the claim. The claimant habitually carried out work in Kinshasa, Democratic Republic of Congo, and the contract was more closely connected with the DRC. England was not the proper forum and the claim was dismissed on the ground of forum non conveniens.

Facts

The claimant, a South African national, was recruited by the UK-based respondent to tutor a family's children in Kinshasa, Democratic Republic of Congo. He worked there from December 2023 to October 2024, apart from a three-week visit to the UK. He was paid in pounds sterling without deductions and paid tax in South Africa. He was given one month's notice and claimed wrongful dismissal for the full contract duration to July 2025. The contract was silent on applicable law.

Decision

The tribunal dismissed the claim for lack of jurisdiction. It found that while the tribunal had international jurisdiction, the claimant habitually worked in Kinshasa, the contract was governed by DRC law, and the circumstances as a whole showed closer connection with the DRC. Applying forum non conveniens principles, England was not the appropriate forum to hear the claim.

Practical note

Employment tribunals can decline jurisdiction over breach of contract claims on forum non conveniens grounds even where international jurisdiction exists, particularly where the claimant habitually worked abroad and the contract is more closely connected with another jurisdiction.

Legal authorities cited

Spiliada Maritime Corpn v Cansulex Ltd [1987] AC 460Prahl and ors v Lapinski 2025 EAT 77Jhuti v Royal Mail Group Ltd and ors 2018 ICR 1077Lawson v Serco [2006] UKHL 3Crofts & Ors v Cathay Pacific Airways Ltd & Ors [2005] EWCA Civ 599Dickie v Cathay Pacific Airways Ltd [2004] ICR 1733

Statutes

Civil Jurisdiction and Judgments Act 1982 s.15CEmployment Tribunals Extension of Jurisdiction (England and Wales) Order 1994 Article 3Employment Tribunals Act 1996 s.3Employment Tribunal Rules of Procedure 2024 Rule 30Employment Tribunal Rules of Procedure 2024 Rule 10Rome I Regulation Article 8

Case details

Case number
6018986/2024
Decision date
30 October 2025
Hearing type
preliminary
Hearing days
1
Classification
contested

Respondent

Sector
education
Represented
Yes
Rep type
in house

Employment details

Role
Private tutor to the Beebee family children
Service
10 months

Claimant representation

Represented
No