Cases6006524/2024

Claimant v JBP Foods Ltd

29 October 2025Before Employment Judge McCooeyReadingremote video

Outcome

Other

Individual claims

Unfair Dismissalnot determined

The tribunal determined at this preliminary hearing that the claimant was an employee for the purposes of s.230 ERA 1996, and therefore has jurisdiction to hear the unfair dismissal claim. The merits have not yet been determined and will be heard at a final hearing in October 2025.

Holiday Paynot determined

The tribunal determined that the claimant was an employee/worker, giving him entitlement to holiday pay claims. The substantive claim will be heard at the final hearing in October 2025.

Facts

The claimant worked as a sales representative for the respondent from July 2020 to February 2024. He was told at interview he would be self-employed and paid by commission. The respondent provided him with a company car, tablet, scanner and catalogue. He was given customers, assigned geographic areas to visit, and his movements were monitored by GPS. When he attempted to assert autonomy on the basis of his self-employed status in late 2022, he was threatened with dismissal by the director. The tribunal had to determine his employment status to establish jurisdiction.

Decision

The tribunal found that despite the label of 'self-employed', the reality of the working relationship was that the claimant was an employee. The respondent exercised significant control over when, where and how he worked, provided the tools of the trade, and when the claimant tried to assert the autonomy of self-employment, was threatened with dismissal. The claims of unfair dismissal and holiday pay can therefore proceed to a full merits hearing.

Practical note

A worker cannot be denied employment rights simply by being labelled 'self-employed' - tribunals will look at the reality of control, personal service obligations, and what happens when a worker attempts to exercise the autonomy that genuine self-employment should provide.

Legal authorities cited

Ready Mixed Concrete v Minister of Pensions [1968] 2 QB 497Bates van Winkelhof v Clyde & Co LLP [2014] UKSC 32Pimlico Plumbers Ltd v Smith [2017] EWCA Civ 51; [2018] UKSC 29Stuart Delivery Ltd v Augustine [2022] ICR 511Richards v Waterfield Homes Ltd [2022] EAT 148Ajar-Tec Ltd v Stack [2012] EWCA Civ 543Autoclenz Ltd v Belcher [2011] UKSC 41

Statutes

Employment Rights Act 1996 s.230(2)Employment Rights Act 1996 s.230(3)Employment Rights Act 1996 s.230(1)

Case details

Case number
6006524/2024
Decision date
29 October 2025
Hearing type
preliminary
Hearing days
1
Classification
contested

Respondent

Sector
retail
Represented
Yes
Rep type
lay rep

Employment details

Role
sales representative
Service
4 years

Claimant representation

Represented
No