Cases6012908/2024

Claimant v Essex County Council

23 May 2025Before Employment Judge D BalroopLondon Eastremote video

Outcome

Claimant fails

Individual claims

Unlawful Deduction from Wagesfailed

The tribunal found that the contract's continuous service date of 13 January 2021 was a clear mistake given the claimant's 20-month employment gap from March 2022 to November 2023. Applying the principles in East v Pantiles, the correct continuous start date was 27 November 2023. With less than 12 months' service at the time of sickness absence, the claimant was not entitled to the enhanced contractual sick pay provisions (3 months full pay and 3 months half pay). Therefore, no unlawful deduction occurred as the respondent was under no obligation to make the payments claimed.

Facts

The claimant worked for the respondent from January 2021 to March 2022, then left to work elsewhere. He re-joined the respondent on 27 November 2023 as an Analyst. His contract stated a continuous service start date of 13 January 2021. When the claimant took sick leave, he claimed entitlement to enhanced contractual sick pay (3 months full pay and 3 months half pay) based on three years' continuous service. The respondent argued the contract date was an error and his continuous service started on 27 November 2023, giving him less than 12 months' service.

Decision

The tribunal held that the continuous service date of 13 January 2021 in the contract was a clear and obvious mistake, given the undisputed 20-month gap in employment from March 2022 to November 2023. Applying the principles from East v Pantiles, the tribunal corrected the date to 27 November 2023 as a matter of contractual construction. With less than 12 months' service, the claimant was not entitled to enhanced sick pay and no unlawful deduction of wages occurred. The claim was dismissed.

Practical note

A tribunal can correct a clear mistake in a contract as a matter of construction without formal rectification proceedings if the error is obvious and the correction is clear, particularly where a literal reading would produce an absurd result inconsistent with undisputed background facts.

Legal authorities cited

East v Pantiles Plant Hire Ltd (1981) 263 EG 61

Statutes

ERA 1996 s.13

Case details

Case number
6012908/2024
Decision date
23 May 2025
Hearing type
full merits
Hearing days
1
Classification
contested

Respondent

Name
Essex County Council
Sector
local government
Represented
Yes
Rep type
barrister

Employment details

Role
Analyst

Claimant representation

Represented
Yes
Rep type
barrister