Cases1401318/2024

Claimant v Stubborn Rhino Ltd

20 October 2025Before Employment Judge ScottSouthampton

Outcome

Partly successful£30

Individual claims

Unlawful Deduction from Wagespartly succeeded

The tribunal found the respondent made an unauthorised deduction from wages on 9 February 2024 by failing to pay national minimum wage for 6.25 hours of travel time (£30.25). Claims for earlier deductions (invoices 1-9) were dismissed as out of time, as the claimant was aware of his rights but chose not to pursue a claim until April 2024, so it was reasonably practicable to claim within the time limit.

Detrimentfailed

The tribunal found the claimant was told his services would no longer be required on 27 February 2024 because he requested payment for travel time at national minimum wage. However, the claim failed because as a casual worker with no overarching contract, the claimant had no current worker contract at the time of the alleged detriment. He had not been formally booked for future events, so there was no contract to terminate.

Facts

Mr Phillips worked as a barista for Stubborn Rhino Ltd on an ad hoc basis from May 2023 to February 2024, invoicing for work completed at events. He negotiated his own rates and could decline work. On 26-27 February 2024, he requested payment for travel time at national minimum wage, citing legal entitlement. Mr Robertson responded the same day that his services would no longer be required. Phillips claimed he was dismissed for asserting his right to minimum wage and that he was owed unpaid travel time.

Decision

The tribunal found Phillips was a worker under discrete contracts for each event, not under an overarching contract. The detriment claim failed because he had no current worker contract when told his services were not required, as he had not been formally booked for future events. The unlawful deduction claim partly succeeded: he was awarded £30.25 for unpaid travel time on 9 February 2024, but earlier claims were dismissed as out of time because it was reasonably practicable to claim earlier.

Practical note

Casual workers without mutuality of obligation may be workers under discrete event-by-event contracts, but cannot claim detriment for losing future work when no contract yet exists for those future engagements.

Award breakdown

Unpaid wages£30

Legal authorities cited

Uber BV v Aslam [2021] UKSC 5Cotswold Developments Construction Ltd v Williams [2006] IRLR 181Pimlico Plumbers Ltd and anor v Smith [2017] ICR 657Stuart Delivery Ltd v Augustine [2022] ICR 511Dedman v British Building and Engineering Appliances Ltd [1974] ICR 53Wall's Meat Co Ltd v Khan [1979] ICR 52Porter v Bandridge Ltd [1978] ICR 943

Statutes

ERA 1996 s.13ERA 1996 s.23National Minimum Wage Act 1998 s.23National Minimum Wage Act 1998 s.24ERA 1996 s.230(3)

Case details

Case number
1401318/2024
Decision date
20 October 2025
Hearing type
full merits
Hearing days
2
Classification
contested

Respondent

Sector
hospitality
Represented
Yes
Rep type
lay rep

Employment details

Role
Barista
Service
10 months

Claimant representation

Represented
No