Cases2212618/2024

Claimant v Troubadour Properties Ltd

1 May 2025Before Employment Judge KeoghLondon Centralremote video

Outcome

Claimant fails

Individual claims

Unfair Dismissalstruck out

Claim struck out on the basis that the tribunal had no territorial jurisdiction. The claimant was ordinarily resident in the USA, working from Massachusetts, and was not an employee working in Great Britain, nor a peripatetic employee based in GB, nor an expatriate employee with sufficiently strong connections to GB to meet the Lawson test. There were no reasonable prospects of success on jurisdiction.

Constructive Dismissalstruck out

Claim struck out on jurisdictional grounds as the tribunal found no reasonable prospect of establishing territorial jurisdiction under the Lawson principles, given the claimant worked and resided in the USA.

Direct Discrimination(sex)struck out

Claim struck out on jurisdictional grounds. The same territorial jurisdiction test applies to Equality Act 2010 claims as to Employment Rights Act claims (Hottak), and the claimant had no reasonable prospect of demonstrating sufficient connection to Great Britain.

Whistleblowingstruck out

Protected disclosure detriment claim struck out on the basis of no territorial jurisdiction. Claimant ordinarily resident and working in the USA with insufficient connection to GB employment law.

Holiday Paystruck out

Holiday pay claim struck out on jurisdictional grounds. Tribunal had no territorial jurisdiction as claimant's place of work was in the USA.

Breach of Contractstruck out

Notice pay claim struck out on jurisdictional grounds along with all other claims.

Unlawful Deduction from Wagesstruck out

Unpaid wages and other payments claims struck out on the basis of no territorial jurisdiction.

Facts

The claimant, a US citizen ordinarily resident and working in Massachusetts, USA, was a director of four UK-based companies (Troubadour entities) until September 2023. She brought claims for unfair dismissal, discrimination, whistleblowing, and various payment claims. The respondents contended she was a self-employed contractor working from the USA. The claimant failed to comply with tribunal directions to prepare evidence for a preliminary hearing on jurisdiction and employment status, seeking multiple postponements citing ill health, work pressures, and financial constraints. At the hearing she attempted to introduce factual evidence for the first time, which the tribunal refused to admit.

Decision

The tribunal struck out all claims on the basis of no territorial jurisdiction. Applying the Lawson principles, the judge found the claimant had no reasonable prospect of establishing jurisdiction: she was not working in Great Britain (paradigm case), nor based in GB (peripatetic), nor did she have sufficiently strong connections as an expatriate employee. The claimant's own case was that she worked from Massachusetts, USA. The tribunal refused to admit late factual evidence introduced on the day of the hearing, finding it would prejudice the respondents and was the result of the claimant's failure to comply with orders without good reason.

Practical note

Claimants working and residing abroad face a high bar to establish UK tribunal jurisdiction, even as directors of UK companies, and must proactively advance a positive case on territorial jurisdiction with proper evidence in compliance with tribunal orders.

Legal authorities cited

Duncombe v Secretary of State for Children, Schools and Families [2011] UKSC 36R. (on the application of Hottak) v Secretary of State for Foreign and Commonwealth Affairs [2016] EWCA Civ 438Ravat v Halliburton Manufacturing & Services Ltd [2012] UKSC 1Lawson v Serco Ltd [2006] UKHL 3

Statutes

EqA 2010 s.83ERA 1996 s.230ERA 1996 s.94(1)

Case details

Case number
2212618/2024
Decision date
1 May 2025
Hearing type
strike out
Hearing days
1
Classification
procedural

Respondent

Sector
real estate
Represented
Yes
Rep type
barrister

Employment details

Role
Director

Claimant representation

Represented
No