Cases2223320/2024

Claimant v 3D Personnel Limited

28 April 2025Before Employment Judge T.R. SmithLondon Centralin person

Outcome

Claimant fails

Individual claims

Unlawful Deduction from Wagesfailed

The tribunal found that the claimant was not an employee or worker of the first respondent but was employed by the second respondent (umbrella company). The documentary evidence and contractual arrangements clearly established the second respondent as the employer, and there was no express or implied contract between the claimant and the first respondent that would support worker or employee status.

Holiday Payfailed

The holiday pay claim against the first respondent failed for the same reason as the wages claim: the tribunal determined the claimant was not an employee or worker of the first respondent. The claimant had a contract of employment with the second respondent which contained holiday pay provisions, making the second respondent the proper respondent for any holiday pay claims.

Facts

The claimant worked as a labourer for approximately two weeks from 27 June to 10 July 2024 in the construction industry. He was placed through the first respondent (an employment agency) but signed a contract of employment with the second respondent (an umbrella company). The claimant brought claims for unauthorised deductions from wages and holiday pay, arguing he was employed by the first respondent. The preliminary hearing determined who the claimant's employer was.

Decision

The tribunal found that the claimant was an employee of the second respondent only, not the first respondent. The documentary evidence, including the contract of employment, P45, and payslips, all pointed to the second respondent as employer. There was no express or implied contract between the claimant and the first respondent that would establish employee or worker status. The claims against the first respondent were dismissed.

Practical note

In tripartite agency/umbrella arrangements, tribunals will scrutinise the contractual documents and actual arrangements to determine employer identity, and clear written contracts superseding earlier preliminary arrangements will be determinative absent evidence of sham or that the reality differs from documentation.

Legal authorities cited

James v Greenwich London Borough Council [2008] ICR 545Ready Mixed Concrete v Minister of Pensions [1968] 2 QB 497Uber BV v Aslam [2021] UKSC 5Carmichael and anor v National Power plc [2000] IRLR 43Cheng Yuen v Royal Hong Kong Gold Club [1998] ICR 131

Statutes

ERA 1996 s.230(1)ERA 1996 s.230(3)ERA 1996 s.230(2)

Case details

Case number
2223320/2024
Decision date
28 April 2025
Hearing type
preliminary
Hearing days
1
Classification
contested

Respondent

Sector
professional services
Represented
Yes
Rep type
in house

Employment details

Role
labourer

Claimant representation

Represented
No