Cases2303374/2024

Claimant v Fine & Country Richmond Ltd

24 April 2025Before Employment Judge TsamadosLondon South Croydonremote video

Outcome

Partly successful

Individual claims

Unfair Dismissaldismissed on withdrawal

Tribunal found the Claimant was not an employee of the Respondents at the relevant time. The complaint of unfair dismissal was dismissed because the Tribunal does not have jurisdiction to determine it.

Wrongful Dismissaldismissed on withdrawal

Tribunal found the Claimant was not an employee of the Respondents at the relevant time. The complaint of wrongful dismissal (relating to notice pay) was dismissed because the Tribunal does not have jurisdiction to determine it.

Unlawful Deduction from Wagesnot determined

Tribunal determined the Claimant was a worker at the relevant time. The Tribunal has jurisdiction to determine this complaint and it will be listed for a further hearing to determine liability and if appropriate remedy.

Holiday Paynot determined

Tribunal determined the Claimant was a worker at the relevant time. The Tribunal has jurisdiction to determine this complaint concerning entitlement to annual leave and it will be listed for a further hearing to determine liability and if appropriate remedy.

Breach of Contractnot determined

Tribunal determined the Claimant was entitled to receive written particulars of employment under sections 1 and 4 of ERA 1996. The Respondents had not provided them. This matter will be determined at a further hearing for liability and remedy.

Facts

The Claimant worked as a Real Estate Agent for two related estate agency companies from December 2020 to February 2024, receiving commission on completed transactions and paying his own tax. He resigned alleging constructive dismissal, claiming unpaid wages, holiday pay and notice pay. The Respondents argued he was self-employed. The arrangement began informally with a fee-split structure and the Claimant had autonomy over when and how he worked, though received leads from the Respondents and attended weekly meetings. Disputes arose over non-payment of fees and an alleged £25,000 acquisition fee the Claimant received directly from a client.

Decision

The tribunal found the Claimant was not an employee but was a worker under s.230 ERA 1996. The claims for unfair and wrongful dismissal were dismissed for lack of jurisdiction. The tribunal has jurisdiction to hear claims for unauthorised deductions from wages, holiday pay and failure to provide written particulars, which will proceed to a further hearing on liability and remedy.

Practical note

Estate agents working on commission with autonomy over working patterns may be workers entitled to holiday pay and wage protection rights even where they are not employees entitled to unfair dismissal protection.

Legal authorities cited

Autoclenz Ltd v Belcher [2011] UKSC 41O'Kelly v Trusthouse Forte [1983] IRLR 369, CACarmichael v National Power [2000] IRLR 43, HLMontgomery v Johnson Underwood [2001] IRLR 269, CAHospital Medical Group Ltd v Westwood [2012] IRLR 834 CAWindle & Anor v SS for Justice [2014] IRLR 914, EATExpress & Echo Publications v Tanton [1999] IRLR 367, CAJohnson v G T Gettaxi (UK) Ltd [2024] EAT 162Ready Mixed Concrete v Minister of Pensions [1968] 2 QB 497Malik v Bank of Credit and Commerce International [1998] AC 20

Statutes

ERA 1996 s.1ERA 1996 s.4Working Time Regulations 1998ERA 1996 s.230

Case details

Case number
2303374/2024
Decision date
24 April 2025
Hearing type
preliminary
Hearing days
2
Classification
contested

Respondent

Sector
real estate
Represented
Yes
Rep type
in house

Employment details

Role
Real Estate Agent
Service
3 years

Claimant representation

Represented
Yes
Rep type
barrister