Cases8000114/2025

Claimant v Edison Group Ltd

4 July 2025Before Employment Judge B CampbellScotlandon papers

Outcome

Claimant fails

Individual claims

Unlawful Deduction from Wagesstruck out

Claim dismissed on 29 April 2025 on the basis it had no reasonable prospects of success. Claimant admitted his employer was Principal Building Limited (in liquidation), not Edison Group Ltd. His argument that Edison Group should be liable because of shared management and intra-group activities was contrary to fundamental principles of company law - each company is a separate legal entity.

Holiday Paystruck out

Claim dismissed on 29 April 2025 on the basis it had no reasonable prospects of success. Claimant's employer was Principal Building Limited which entered liquidation on 30 December 2024. No legal basis existed to hold Edison Group Ltd liable for employment debts of a separate company in the same group.

Wrongful Dismissalstruck out

Claim for notice pay dismissed on 29 April 2025 on the basis it had no reasonable prospects of success. The respondent named in the claim (Edison Group Ltd) was not the claimant's employer and the actual employer (Principal Building Limited) was in liquidation.

Breach of Contractstruck out

Claim dismissed on 29 April 2025 on the basis it had no reasonable prospects of success. Despite claimant's evidence of shared activities across the corporate group, there was no legal basis to pierce the corporate veil or hold Edison Group Ltd liable for contractual obligations owed by the separate legal entity Principal Building Limited.

Facts

Claimant sought payment of salary, benefits, holidays and notice from his former employer Principal Building Limited, which entered liquidation on 30 December 2024. Unable to serve PBL, he attempted to pursue Edison Group Ltd, the parent company sharing directors with PBL. Claimant argued that shared management, intertwined operations and common directors meant Edison Group should be liable. The claim was dismissed on 29 April 2025 for having no reasonable prospects. Claimant applied for reconsideration and respondent sought costs.

Decision

Tribunal refused reconsideration application, finding no reasonable prospect of success. Despite claimant's extensive evidence of intra-group activities, fundamental company law principles meant each company was a separate legal entity and Edison Group could not be liable for PBL's employment debts. Tribunal also refused costs application against claimant - although claim had no prospects, claimant genuinely believed it could succeed and could not reasonably have been expected to know otherwise as a layperson.

Practical note

Corporate group structures do not allow tribunals to disregard separate legal personality and hold a parent company liable for a subsidiary's employment debts, even where there are common directors and shared business functions.

Legal authorities cited

Autoclenz Limited v Belcher and others UKEAT/0160/08Radia v Jefferies International Ltd UKEAT/0007/18

Statutes

Transfer of Undertakings (Protection of Employment) Regulations 2006Employment Tribunal Procedure Rules 2024 rules 73-74Employment Tribunal Procedure Rules 2024 rules 68-71

Case details

Case number
8000114/2025
Decision date
4 July 2025
Hearing type
reconsideration
Hearing days
Classification
procedural

Respondent

Sector
construction
Represented
No
Rep type
in house

Claimant representation

Represented
No