Cases8002073/2024

Claimant v Envirosan Limited

8 April 2025Before Employment Judge D HoeyScotlandin person

Outcome

Claimant fails

Individual claims

Unlawful Deduction from Wagesstruck out

The tribunal found that any contractual relationship ended by March 2022 when claimant was no longer offered work or paid. Claim was filed 2 years 9 months out of time. It was reasonably practicable for claimant to have filed within 3 months as she knew of the time limits, was articulate and intelligent, and had access to legal advice. She chose not to pursue a claim at the time due to family disputes and concern for her mental health, but this was a choice rather than an impediment. Claim dismissed as time-barred.

Facts

Claimant received £975 monthly from November 2019 to February 2022 (£11,000 per year) via informal arrangement made between her husband and his father who were directors of respondent, ostensibly for consultancy work. No written contract or clear duties. General manager (who became director in March 2022) had no knowledge of claimant working for respondent and discovered payments were made for tax efficiency purposes. Payments ceased March 2022. Claimant set up own business immediately after. Nine months later claimant queried her employment status having been told relationship could not end without P45 or dismissal letter. Claim filed December 2024.

Decision

Tribunal found no genuine contractual relationship existed between claimant and respondent - arrangement was for tax purposes only with no clear mutual obligations. Even if relationship existed, it ended by March 2022 when payments and work ceased. Claim filed 2 years 9 months late. It was reasonably practicable for claimant to file in time as she knew of 3-month time limit, was articulate and intelligent, and had legal advice access. She chose not to pursue claim due to family disputes and mental health concerns. Claim dismissed as time-barred.

Practical note

A tribunal will look objectively at parties' conduct to determine if employment has been terminated even without formal dismissal letter, and where claimant knows of time limits but chooses not to pursue claim for personal reasons, this will not make late filing reasonably practicable.

Legal authorities cited

Porter v Bandridge Ltd [1978] ICR 943Trevelyans (Birmingham) Ltd v Norton [1991] ICR 488Kirklees Metropolitan Council v Radecki [2009] ICR 1244Hogg v Dover College [1990] ICR 39Sandle v Adecco UK Ltd [2016] IRLR 941Avuru v Favernmead Ltd EAT 0312/19Lowri Beck Services v Brophy [2019] EWCA Civ 2490Marks and Spencer plc v Williams-Ryan [2005] EWCA Civ 470Palmer and Saunders v Southend-on-Sea Borough Council [1984] IRLR 119Wall's Meat Co Ltd v Khan [1979] ICR 52Dedman v British Building and Engineering Appliances Ltd [1974] ICR 53

Statutes

Employment Rights Act 1996 s.23Employment Rights Act 1996 s.13

Case details

Case number
8002073/2024
Decision date
8 April 2025
Hearing type
preliminary
Hearing days
1
Classification
contested

Respondent

Sector
other
Represented
Yes
Rep type
barrister

Employment details

Role
Consultancy services
Salary band
Under £15,000
Service
2 years

Claimant representation

Represented
No