Cases2301243/2025

Claimant v Tribal EMEA Limited

30 September 2025Before Employment Judge LumbyCroydonremote video

Outcome

Claimant fails

Individual claims

Unfair Dismissalwithdrawn

Withdrawn by claimant as he had less than two years' qualifying service, which is required to bring an unfair dismissal claim.

Breach of Contractstruck out

The claim was recast as breach of implied term of trust and confidence to circumvent the two-year qualifying rule for unfair dismissal. The tribunal found it had no reasonable prospect of success and struck it out, as the alleged loss of opportunity to apply for other jobs could not support such a claim.

Failure to Inform & Consultstruck out

The claim under TUPE Regulation 7(1) was dismissed for want of jurisdiction, as employees with less than two years' service cannot bring such claims. The tribunal also found that even if it had jurisdiction, the claim had no reasonable prospect of success. A late attempt to recast it under ERA 1996 s.104 was rejected as no amendment had been made.

Holiday Paynot determined

The claimant's case was unclear, claiming 7.8 days unpaid holiday without explanation and without deducting an additional day paid by the respondent. The tribunal found a genuine dispute requiring examination and declined to strike it out, instead making an unless order requiring clarification within two weeks.

Facts

The claimant brought claims including unfair dismissal, breach of contract (recast as breach of implied term of trust and confidence), breach of TUPE Regulations, and holiday pay. He had less than two years' qualifying service. The unfair dismissal claim was withdrawn. At a preliminary hearing on 12 September 2025, the respondent applied for strike-out. The claimant persisted with the remaining claims despite cost warning letters sent on 4, 8, 9 and 10 September 2025. The claimant was represented by solicitors (Portways) and counsel.

Decision

The tribunal struck out the TUPE claim for want of jurisdiction (employees with less than two years' service cannot bring Regulation 7(1) claims) and alternatively for no reasonable prospect of success. The breach of trust and confidence claim was struck out as a transparent attempt to circumvent the two-year qualifying rule with no reasonable prospect of success. The holiday pay claim continued, subject to an unless order requiring clarification. The tribunal awarded costs of £4,381.08 against the claimant for unreasonably pursuing hopeless claims despite warnings, declining to take his financial circumstances into account.

Practical note

Legally represented claimants who persist with claims that have no reasonable prospect of success after clear cost warnings face significant costs liability, even if impecunious, particularly where claims appear designed to circumvent statutory qualifying periods.

Legal authorities cited

Gee v Shell UK Ltd [2003] IRLR 82Monaghan v Close Thornton [2002] EAT/0003/01Brooks v Nottingham University Hospitals NHS Trust [2019] UKEAT/0246/18NPower Yorkshire Ltd v Daley EAT/0842/04Arrowsmith v Nottingham Trent University [2011] ICR 159 CAAQ Ltd v Holden [2012] IRLR 648 EATKapoor v Governing Body of Barnhill Community High School UKEAT/0352/13Barnsley BC v Yerrakalva [2012] IRLR 78 CAShield Automotive Ltd v Greig UKEAT/0024/10Jilley v Birmingham and Solihull Mental Health NHS Trust [2008] UKEAT/0584/06Single Homeless Project v Abu [2013] UKEAT/0519/12Vaughan v LB of Newham [2013] IRLR 713Raggett v John Lewis plc [2012] IRLR 906 EATLadak v DRC Locums Ltd [2014] IRLR 851 EATGrowcott v Glaze Auto Ltd UKEAT/0419/11/SM

Statutes

TUPE Regulations Regulation 7(1)Employment Tribunals Rules of Procedure 2024 Rule 74(2)Employment Tribunals Rules of Procedure 2024 Rule 75Employment Tribunals Rules of Procedure 2024 Rule 76(1)Employment Tribunals Rules of Procedure 2024 Rule 82Civil Procedure Rules 1998Employment Rights Act 1996 s.104

Case details

Case number
2301243/2025
Decision date
30 September 2025
Hearing type
strike out
Hearing days
1
Classification
procedural

Respondent

Sector
technology
Represented
Yes
Rep type
barrister

Claimant representation

Represented
Yes
Rep type
barrister