Cases1308185/2023

Claimant v Rugby Farmers Mart Limited

3 April 2025Before Employment Judge AkhtarBirminghamin person

Outcome

Claimant fails

Individual claims

Unfair Dismissaldismissed on withdrawal

The tribunal found the claimant was neither an employee nor a worker, and therefore had no jurisdiction to hear the unfair dismissal claim. The claim was dismissed as the claimant did not have the requisite employment status.

Direct Discrimination(age)dismissed on withdrawal

The tribunal found the claimant was neither an employee nor a worker within the meaning of the Equality Act 2010, and therefore had no jurisdiction to hear the age discrimination claim. The claim was dismissed as the claimant did not have the requisite employment status.

Breach of Contractdismissed on withdrawal

The tribunal found the claimant was not an employee, and therefore had no entitlement to a statement of written terms under section 1 ERA 1996. The claim was dismissed due to lack of employment status.

Breach of Contractdismissed on withdrawal

The tribunal found the claimant was neither an employee nor a worker, and therefore had no entitlement to notice pay. The claim was dismissed due to lack of employment status.

Holiday Paydismissed on withdrawal

The tribunal found the claimant was neither an employee nor a worker, and therefore had no entitlement to holiday pay under the Working Time Regulations. The claim was dismissed due to lack of employment status.

Facts

The claimant worked for the respondent, a livestock market, from May 2008 to July 2023 performing cleaning and droving duties on market days. He was paid £12.50 per hour via weekly invoices with VAT, set his own hours, chose when to attend, and was never subject to PAYE. He ran his own farming business simultaneously. The respondent considered him self-employed, though the claimant argued he was an employee or at minimum a worker.

Decision

The tribunal held the claimant was neither an employee nor a worker. The tribunal found he was not required to provide personal service as he could substitute (as evidenced by another contractor doing so), there was no mutuality of obligation as he chose which days to work and could decline work, and the respondent exercised insufficient control as he determined his own hours and methods of work. The relationship was one of business-to-business with the respondent as a client.

Practical note

A long-standing working relationship and regular attendance pattern is insufficient to establish employment or worker status where the individual has genuine freedom to substitute, no obligation to accept work, control over their own working hours and methods, and operates their own business in parallel.

Legal authorities cited

Commissioners for HMRC v Professional Game Match Officials Ltd [2024] UKSC 29Humberstone v Northern Timber Mills (1949) 79 CLR 389White v Troutbeck SA [2013] EWCA Civ 1171Ready Mixed Concrete (Southeast) Limited v Minister of Pensions and National Insurance [1968]Byrne Brothers (Formwork) Ltd v Baird [2002] IRLR 96Uber BV v Aslam UKSC/2019/0029

Statutes

EqA 2010 s.83(2)(a)ERA 1996 s.230(3)(b)ERA 1996 s.230(1)

Case details

Case number
1308185/2023
Decision date
3 April 2025
Hearing type
preliminary
Hearing days
1
Classification
contested

Respondent

Sector
agriculture
Represented
Yes
Rep type
barrister

Employment details

Role
Cleaning and droving work (moving livestock)
Service
15 years

Claimant representation

Represented
Yes
Rep type
barrister