Cases3312412/2023

Claimant v Cleaners Clean

15 June 2025Before Employment Judge QuillWatfordin person

Outcome

Other

Individual claims

Unfair Dismissalnot determined

This was a preliminary hearing on applications to strike out. The tribunal declined to strike out the unfair dismissal claim against any respondent, finding the claimant had better than little reasonable prospects of showing he was unfairly dismissed, though the identity of the employer at the date of dismissal remained to be determined at final hearing.

Redundancy Paynot determined

The tribunal declined to strike out this claim, finding the claimant had better than little reasonable prospects of showing entitlement to a redundancy payment, subject to determination of who the employer was and whether there was in fact a redundancy situation.

Breach of Contractnot determined

The tribunal made no formal decision as to whether the claim form included a complaint of breach of contract (likely notice pay), but did not strike out any potential such claim. The issue of entitlement to notice remained to be determined.

Facts

The claimant worked as a cleaner employed by R2 (Ashley Cleaning Services) at R3's (Albion & East / Martello Hall) premises for over 2 years until around 30-31 August 2023. He was R2's only employee performing this work. On 31 August 2023 he arrived at work to find someone else doing his job. R2 alleged his employment had TUPE transferred to a new contractor. R3 alleged it had contracted with 'Cleaners Clean' (R1) or possibly other successor entities. The identity of the claimant's employer at termination and whether TUPE applied were disputed.

Decision

The tribunal refused applications by R2 and R3 to strike out the claims against them, finding the claimant had better than little reasonable prospects of succeeding. The tribunal held that complex factual questions about TUPE transfer, the identity of any transferee, and whether activities were fundamentally the same could not be determined without a full merits hearing with witness evidence. The tribunal also refused R3's application for 'default judgment' against R4.

Practical note

Strike out applications in TUPE cases involving disputes about transferee identity and whether activities are fundamentally the same will rarely succeed where core facts turn on witness evidence not yet heard.

Legal authorities cited

Blockbuster Entertainment v James [2006] IRLR 630Limoine v Sharma UKEAT/0094/19Cox v Adecco UKEAT/0339/19/ATABN Amro Management Services v Hogben UKEAT/0266/09Community Law Clinics v Methuen UKEAT/0024/11Ahir v British Airways [2017] EWCA Civ 1392Mechkarov v Citibank N.A [2016] ICR 1121Anyanwu v South Bank University [2001] ICR 391

Statutes

TUPE 2006 Reg 3ERA 1996 s.230ERA 1996 s.164ERA 1996 s.163ERA 1996 s.98ERA 1996 s.94ET Rules 2024 Rule 38ET Rules 2024 Rule 40ET Rules 2024 Rule 22TUPE 2006 Reg 7

Case details

Case number
3312412/2023
Decision date
15 June 2025
Hearing type
preliminary
Hearing days
1
Classification
contested

Respondent

Sector
professional services
Represented
No

Employment details

Role
cleaner
Service
2 years

Claimant representation

Represented
Yes
Rep type
lay rep