Cases8001803/2024

Claimant v S Myles and A Myles T/a Butterflies Nursery School Emmock Woods

15 October 2025Before Employment Judge Jane PorterScotlandin person

Outcome

Claimant fails

Individual claims

Unfair Dismissalstruck out

The tribunal found it lacked jurisdiction to hear the unfair dismissal claim because the claimant had only 4 months' service with her employer (Butterflies Nursery School Emmock Woods) from 5 March 2024 to 12 July 2024, falling short of the two-year qualifying period required under s.108 ERA 1996. The tribunal rejected arguments that the two nurseries were associated employers or that employment had continued from the earlier employer.

Facts

The claimant worked for Butterflies Nursery School Kingsway East from September 2022. In March 2024, she requested and was granted a transfer to the sister nursery, Butterflies Nursery School Emmock Woods, operated by a different partnership, because her child attended Kingsway East. She signed a new contract stating her employment with Emmock Woods began 5 March 2024 with continuous service from that date. She was dismissed on 12 July 2024, having worked only four months for Emmock Woods. She claimed her service should include her earlier employment at Kingsway East.

Decision

The tribunal dismissed the unfair dismissal claim for lack of jurisdiction. The claimant had only four months' service with her employer (Emmock Woods partnership), well short of the two-year qualifying period. The tribunal rejected arguments that the two nurseries were associated employers or that her employment had continued from Kingsway East, finding the two nurseries were separate legal entities and the signed contract clearly identified Emmock Woods as her employer from 5 March 2024.

Practical note

An employee who transfers between two nurseries operated by separate partnerships, even if they share common partners, will not have continuity of service preserved unless the partnerships qualify as 'associated employers' under s.231 ERA 1996, which requires them to be companies, not partnerships.

Legal authorities cited

Wynne v Hair Control [1978] ICR 870Collison v BBC [1998] IRLR 238Southwood Hostel Management Committee v Taylor [1979] IRLR 397Merton London Borough Council v Gardiner [1982] ICR 186Glasgow City Council v Unison [2014] IRLR 532Tice v Cartwright [1999] ICR 769

Statutes

ERA 1996 s.108ERA 1996 s.231ERA 1996 s.218(6)

Case details

Case number
8001803/2024
Decision date
15 October 2025
Hearing type
preliminary
Hearing days
1
Classification
contested

Respondent

Sector
education
Represented
Yes
Rep type
lay rep

Employment details

Service
4 months

Claimant representation

Represented
Yes
Rep type
solicitor