Cases3310739/2023

Claimant v Mr I Williams

15 July 2025Before Employment Judge S MooreCambridgeremote video

Outcome

Other

Individual claims

Automatic Unfair Dismissalnot determined

The tribunal determined it had territorial jurisdiction and English law applies. The strike-out and deposit order applications were dismissed. The claim will proceed to a full merits hearing to determine disputed facts regarding the claimant's working conditions, pay, and the circumstances of her leaving employment.

Constructive Dismissalnot determined

The tribunal dismissed the respondents' strike-out application, finding there is a crucial core of disputed facts concerning the circumstances in which and reasons why the claimant left the respondents' home in the early hours of 21 March 2023 which must be determined at a full hearing.

Unlawful Deduction from Wagesnot determined

The tribunal found there are disputed facts as regards the claimant's pay which need to be determined at a full merits hearing. The claimant alleges she worked 127 days at 19 hours per day and was paid only £300 in total.

Breach of Contractnot determined

The tribunal determined it has jurisdiction to hear the breach of contract claim under the Extension of Jurisdiction Order 1994. The claim turns on disputed facts regarding the claimant's working conditions and the circumstances of termination, to be determined at full hearing.

Holiday Paynot determined

The claim for holiday pay under regulation 14 of the Working Time Regulations 1998 was not struck out and will proceed to a full hearing to determine the factual disputes.

Working Time Regulationsnot determined

The claims for breach of the Working Time Regulations (regulations 10, 11 & 12) were not struck out and will be determined at a full merits hearing following evaluation of all the evidence.

Harassment(sex)not determined

The tribunal rejected the strike-out application, finding that the factual allegations forming the basis of the harassment related to sex and/or sexual harassment complaints are plainly capable of amounting to either or both, and whether the allegations are true and whether they amounted to harassment are questions which need to be determined by hearing evidence at a final hearing.

Othernot determined

Claims for failure to provide a written statement of terms and conditions of employment and itemised payslips under sections 1 & 8 ERA will proceed to a full hearing to determine the disputed facts.

Facts

The claimant, a Nigerian citizen, was engaged as a domestic worker by the respondents from 14 November 2022 to 20 March 2023. She alleges she worked 127 days for 19 hours per day and was paid only £300, was subjected to poor treatment and abuse, and was sexually harassed by Mr Williams. She escaped from the house on 21 March 2023 after being told she would be sent back to Nigeria. The respondents applied to strike out her claims or for a deposit order, arguing jurisdictional issues and that the claimant's visa was obtained fraudulently.

Decision

The tribunal determined it has territorial jurisdiction to hear the claim as the claimant performed her work in England, and English law applies under the Rome 1 Regulation. The tribunal dismissed the strike-out and deposit order applications, finding there is a crucial core of disputed facts regarding the claimant's working conditions, pay, and the circumstances of her departure which must be determined at a full merits hearing. The question of whether the claimant's contract is unenforceable due to illegality was deferred to the final hearing.

Practical note

Where a domestic worker performs all their work in Great Britain, the Employment Tribunal has territorial jurisdiction regardless of visa status or potential fraud in the visa application, and strike-out applications will be dismissed where there are core disputed facts that can only be properly resolved at a full merits hearing.

Legal authorities cited

Uber BV v Aslam [2021] UKSC 5Lawson v Serco [2006] 1 ALL ER 823 (HL)Ravat v Halliburton Manufacturing Services Ltd [2012] IRLR 315 (UKSC)R(Hottak) v Secretary of State [2016] 1 WLR 3791 (CA)Ravisy v Simmons & Simmons LLP (UKEAT/0085/18)Cox v Adecco [2021] ICR 1307QDOS Consulting Ltd v Swanson UKEAT/0495/11Kwele-Siakam v Cooperative Group Ltd UKEAT/0039/17Simpson v Air Business Ltd EAT 0009/19Hemdan v Ishmail & Megraby UKEAT/0021/16/DMCohen v Sandhu EAT 494/80Okedina v Chikale [2019] ICR 1635, CAZarkasi v Anindita [2012] ICR 788, EATHounga v Allan [2014] ICR 847, SCRelfo v Varsani [2009] EWHC 2297

Statutes

EqA 2010 s.26National Minimum Wages Act 1998ERA 1996 s.98ERA 1996 s.104(1)(b)ERA 1996 s.104A(1)(a)ERA 1996 ss.13 & 23ERA 1996 ss.1 & 8Working Time Regulations 1998 reg 14Working Time Regulations 1998 regs 10, 11 & 12

Case details

Case number
3310739/2023
Decision date
15 July 2025
Hearing type
preliminary
Hearing days
3
Classification
contested

Respondent

Sector
other
Represented
Yes
Rep type
lay rep

Employment details

Role
domestic worker
Service
4 months

Claimant representation

Represented
Yes
Rep type
barrister