Cases3302994/2023

Claimant v Van Arthur Flower Group Limited

9 October 2025Before Employment Judge FrenchWatford

Outcome

Partly successful

Individual claims

Unfair Dismissalstruck out

The claimant was not an employee for the purposes of section 230(1) Employment Rights Act 1996, so could not bring an unfair dismissal claim. Additionally, the claimant did not have two years qualifying service and was not asserting any statutory right that would make the dismissal automatically unfair.

Direct Discrimination(race)not determined

The tribunal found that the claimant was in employment within the meaning of the Equality Act 2010 because she was under a contract personally to do work pursuant to s83(2)(a), therefore the race discrimination claims proceed to a full hearing.

Facts

Miss Smith brought claims of unfair dismissal and race discrimination against Van Arthur Flower Group Limited. At a preliminary hearing, the tribunal examined her employment status. She was found not to be an employee under the Employment Rights Act 1996 definition and lacked the two years qualifying service required for ordinary unfair dismissal protection. She was not asserting any statutory right that would make her dismissal automatically unfair.

Decision

The tribunal struck out the unfair dismissal claim due to lack of employee status and qualifying service. However, the race discrimination claims were allowed to proceed because the claimant was found to be in employment under the Equality Act 2010, having a contract personally to do work under section 83(2)(a).

Practical note

Worker status under the Equality Act 2010 is broader than employee status under the Employment Rights Act 1996, allowing individuals without employee status to bring discrimination claims even when unfair dismissal claims are unavailable.

Legal authorities cited

Statutes

ERA 1996 s.230(1)ERA 1996 s.104(4)ERA 1996 s.108EqA 2010 s.83(2)(a)

Case details

Case number
3302994/2023
Decision date
9 October 2025
Hearing type
preliminary
Hearing days
1
Classification
contested

Respondent

Sector
retail
Represented
No
Rep type
in house

Claimant representation

Represented
No