Cases8002099/2024

Claimant v RJW Retail Ltd

3 April 2025Before Employment Judge D N JonesScotlandremote video

Outcome

Claimant fails

Individual claims

Otherfailed

The tribunal concluded that the claimant was not an employee for the purposes of section 230 Employment Rights Act 1996. He was a 100% shareholder and director with no written contract, no one to report to, complete discretion over when he worked and took holidays, and decided whether to take wages. There was no degree of control by anyone else and no contract of employment either express or implied existed.

Facts

The claimant was the founder and 100% shareholder (later 50% shareholder) of a retail company selling personalised gifts from 2011 to 2024. He had no written employment contract, paid himself irregular wages of £800/month (below minimum wage), decided his own hours and holidays, and used company funds for personal expenses which he later repaid. When the company entered creditors voluntary liquidation in October 2024, he claimed insolvency payments from the Secretary of State, arguing he was an employee.

Decision

The tribunal found the claimant was not an employee for the purposes of section 230 ERA 1996. Despite P60s and furlough during COVID, the absence of any control, lack of written contract, complete autonomy over work and pay, and use of company account for personal matters demonstrated no contract of employment existed. The claim failed.

Practical note

A director-shareholder with complete control over their work, pay and conditions, even if receiving regular salary and P60s, will not be considered an employee without genuine mutuality of obligation and a degree of control.

Legal authorities cited

Ready Mixed Concrete v Minister of Pensions [1968] 2 QB 497Clark v Clark Construction Initiatives Ltd [2008] ICR 635Secretary of State v Neufeld [2009] EWCA Civ 280Autoclenz Ltd v Belcher [2011] UKSC 41

Statutes

ERA 1996 s.230

Case details

Case number
8002099/2024
Decision date
3 April 2025
Hearing type
full merits
Hearing days
1
Classification
contested

Respondent

Sector
retail
Represented
No

Employment details

Role
Director/Shareholder
Salary band
Under £15,000
Service
14 years

Claimant representation

Represented
No