Cases6007872/2024

Claimant v AC

17 September 2025Before Employment Judge Isabel ManleyReadingremote video

Outcome

Claimant fails

Individual claims

Direct Discrimination(religion)struck out

Struck out because the claims have no reasonable prospect of success and are an abuse of process due to res judicata estoppel arising from the Financial Remedies Order dated 23 October 2023. In the alternative, the claimant was self-employed and not a worker or employee under ERA 1996 or EqA 2010.

Direct Discrimination(marriage civil partnership)struck out

Struck out because the claims have no reasonable prospect of success and are an abuse of process due to res judicata estoppel arising from the Financial Remedies Order dated 23 October 2023. In the alternative, the claimant was self-employed and not a worker or employee under ERA 1996 or EqA 2010.

Discrimination Arising from Disability (s.15)(disability)struck out

Struck out because the claims have no reasonable prospect of success and are an abuse of process due to res judicata estoppel arising from the Financial Remedies Order dated 23 October 2023. In the alternative, the claimant was self-employed and not a worker or employee under ERA 1996 or EqA 2010.

Failure to Make Reasonable Adjustments(disability)struck out

Struck out because the claims have no reasonable prospect of success and are an abuse of process due to res judicata estoppel arising from the Financial Remedies Order dated 23 October 2023. In the alternative, the claimant was self-employed and not a worker or employee under ERA 1996 or EqA 2010.

Unlawful Deduction from Wagesstruck out

Claim for £39,199 between February 2022 and April 2024 struck out because the claims have no reasonable prospect of success and are an abuse of process due to res judicata estoppel arising from the Financial Remedies Order dated 23 October 2023. In the alternative, the claimant was self-employed and not a worker or employee under ERA 1996.

Facts

The claimant, a dentist, co-owned a dental practice with her ex-husband (first respondent) holding a 50% shareholding. They separated in 2020 and divorced in 2022. On 23 October 2023 a Financial Remedies Order was made by the Family Court requiring the claimant to transfer her shares and resign from employment by 30 April 2024. The FRO contained a clause settling all claims between the parties. The claimant worked as a dentist receiving 50% of fees she collected until she left on 29 April 2024. She brought claims for religious and marital discrimination, disability discrimination, and unlawful deduction of wages in August 2024.

Decision

The tribunal struck out all claims on two grounds: first, the Financial Remedies Order created a res judicata estoppel preventing the claims as an abuse of process. Second, even if the FRO did not bar the claims, the claimant was self-employed throughout and not a worker or employee under ERA 1996 or EqA 2010, being in business on her own account as a 50% shareholder co-owner until October 2023, and thereafter continuing to provide dental services as a client/customer relationship with the practice.

Practical note

A Financial Remedies Order from the Family Court containing a full and final settlement clause can create a res judicata estoppel preventing subsequent employment tribunal claims, even where there is no formal settlement agreement under ERA or EqA provisions.

Legal authorities cited

Ready Mixed Concrete v Minister of Pensions [1968] 2 QB 497Carmichael v National Power plc [1999] ICR 1226Pimlico Plumbers Limited v Smith [2017] EWCA Civ 51Pimlico Plumbers Limited v Smith [2018] UKSC 29Allsop v Banner Jones Ltd [2021] EWCA Civ 7Sejpal v Rodericks Dental Limited [2022] EAT 91Young & Woods Ltd v West [1980] IRLR 201Richards v Waterfields Ltd [2023] IRLR 145Uber BV v Aslam [2021] UKSC 5Autoclenz Ltd v Belcher [2011] UKSC 41

Statutes

ERA 1996 s.230EqA 2010 s.83ERA 1996 s.203EqA 2010 s.144EqA 2010 s.147

Case details

Case number
6007872/2024
Decision date
17 September 2025
Hearing type
preliminary
Hearing days
2
Classification
contested

Respondent

Name
AC
Sector
healthcare
Represented
Yes
Rep type
barrister

Employment details

Role
Dentist
Service
19 years

Claimant representation

Represented
No