Cases6018751/2024

Claimant v 1PhysioUK Limited

14 May 2025Before Employment Judge HeatherNewcastleremote video

Outcome

Claimant succeeds£20,037

Individual claims

Breach of Contractsucceeded

Tribunal found respondent was not entitled to invoke short-time working clause as there was never a temporary shortage of work. The shortage was almost permanent throughout employment. Respondent failed to pay claimant contractual 37.5 hours per week, constituting breach of contract.

Unlawful Deduction from Wagessucceeded

Respondent imposed a 'fines' system unilaterally without contractual authority. Claimant explicitly objected in writing. Deductions were not authorised by statute, contract, or written agreement. The variation clause could not reasonably permit such unilateral imposition of fines given unequal bargaining position.

Holiday Paysucceeded

Claimant entitled to 4.11 weeks accrued but untaken holiday on termination, calculated by reference to contracted hours not actually worked hours. Tribunal found respondent failed to pay claimant for this accrued leave, amounting to unauthorised deduction.

Facts

Claimant, a Pakistani physiotherapist, was recruited to UK in 2023 on a sponsored visa with contract for 37.5 hours/week at £25,600 p.a. From outset, respondent paid him for far fewer hours (typically 10 hours/week initially, later reduced to 8 hours/week on Saturdays only). Respondent imposed unilateral 'fines' system in November 2023 threatening £100 penalties for administrative failures. Claimant objected but deductions were made. Respondent offered alternative work in distant cities without travel/accommodation costs. Claimant resigned in August 2024 after his hours were further reduced.

Decision

Tribunal found respondent's reliance on short-time working clause invalid because shortage of work was never temporary but almost permanent throughout employment. Respondent therefore in breach of contract for failing to provide/pay for 37.5 hours weekly. Unilateral imposition of fines system was unauthorised deduction from wages. Holiday pay calculated on contracted not actual hours worked. Total award £20,037.22.

Practical note

Short-time working clauses must be strictly construed: 'temporary' shortage means genuinely short-lived, not a permanent or near-permanent reduction in hours lasting throughout employment; variation clauses cannot be used to impose unilateral penalty systems on sponsored migrant workers in vulnerable positions.

Award breakdown

Holiday pay£2,023
Unpaid wages£93

Award equivalent: 40.7 weeks' gross pay

Legal authorities cited

Hart v St Mary's School (Colchester) Ltd [2014] UKEAT/0305/14/DMGreg May (Carpet Fitters and Contractors) Ltd v Dring [1990] ICR 188Agarwal v Cardiff University [2019] ICR 433 CAChief Constable of the Police Service of Northern Ireland v Agnew [2023] UKSC 33Birmingham City Council v Wetherill [2007] IRLR 781 CAWhite & Carter (Councils) v McGregor [1962] AC 413

Statutes

Working Time Regulations 1998 reg.13Employment Rights Act 1996 s.221-224Employment Rights Act 1996 s.24Employment Rights Act 1996 s.23Employment Rights Act 1996 s.13Working Time Regulations 1998 reg.16Transfer of Undertakings (Protection of Employment) Regulations 2006 reg.3 and 4Employment Tribunals Extension of Jurisdiction (England and Wales) Order 1994 art.3Working Time Regulations 1998 reg.14Working Time Regulations 1998 reg.13A

Case details

Case number
6018751/2024
Decision date
14 May 2025
Hearing type
full merits
Hearing days
1
Classification
contested

Respondent

Sector
healthcare
Represented
Yes
Rep type
in house

Employment details

Role
Musculoskeletal Physiotherapist
Salary band
£25,000–£30,000
Service
1 years

Claimant representation

Represented
Yes
Rep type
barrister