Cases2600705/2024

Claimant v SBFM Group Limited

13 March 2025Before Employment Judge SinghMidlands Eastin person

Outcome

Claimant fails

Individual claims

Failure to Inform & Consultstruck out

Claim arose from TUPE transfer on 1 September 2022. Tribunal found it was not reasonably practicable to submit in time (claimant ignorant of right until employment ended December 2023), but claim not submitted within reasonable further period - claimant received ACAS certificate 8 March 2024 but submitted claim 9 April 2024, one day after one-month extension expired. Dismissed for lack of jurisdiction.

Unfair Dismissalstruck out

Claim out of time - EDT 8 December 2023, ACAS certificate 8 March 2024, claim submitted 9 April 2024 (one day late). Tribunal found it was reasonably practicable to submit in time - claimant had union advice, no障礙 preventing submission. Time limit could not be extended. Dismissed for lack of jurisdiction.

Breach of Contractstruck out

Notice pay claim out of time - EDT 8 December 2023, ACAS certificate 8 March 2024, claim submitted 9 April 2024 (one day late). Tribunal found it was reasonably practicable to submit in time. Time limit could not be extended. Dismissed for lack of jurisdiction.

Holiday Paystruck out

Claim out of time - EDT 8 December 2023, ACAS certificate 8 March 2024, claim submitted 9 April 2024 (one day late). Tribunal found it was reasonably practicable to submit in time. Time limit could not be extended. Dismissed for lack of jurisdiction.

Unlawful Deduction from Wagesstruck out

Claimant alleged non-payment since 1 September 2022. Tribunal treated last deduction date as 8 December 2023 (termination date). Claim submitted 9 April 2024 (one day late). Tribunal found it was reasonably practicable to submit in time. Time limit could not be extended. Dismissed for lack of jurisdiction.

Facts

Claimant's employment transferred from second respondent to first respondent on 1 September 2022 under TUPE. First respondent initially denied employment but conceded in December 2024. Claimant's employment ended 8 December 2023 when gym access was revoked. Claimant received union advice in January 2024, contacted ACAS 22 February 2024, received certificate 8 March 2024, and submitted claim 9 April 2024 - one day late.

Decision

All claims dismissed as out of time. TUPE consultation claim not submitted within reasonable further period after claimant became aware of rights. Dismissal-related claims were one day late and tribunal found it was reasonably practicable to submit in time - claimant had union advice and no obstacle preventing timely submission.

Practical note

Missing an employment tribunal time limit by even one day can be fatal to a claim where the tribunal finds it was reasonably practicable to submit in time, especially where the claimant had access to professional advice.

Legal authorities cited

Palmer v Southend-on-Sea Borough Council [1984] ICR 372

Statutes

ERA 1996 s.111(2)TUPE Reg 15(12)ERA 1996 s.23ERA 1996 s.207B(4)Employment Tribunals Act 1996 s.18AEmployment Tribunals Extension of Jurisdiction (England & Wales) Order 1994 s.7Working Time Regulations 1998 Reg 30(2)

Case details

Case number
2600705/2024
Decision date
13 March 2025
Hearing type
preliminary
Hearing days
2
Classification
contested

Respondent

Sector
professional services
Represented
Yes
Rep type
barrister

Employment details

Role
cleaner (gym facility)

Claimant representation

Represented
Yes
Rep type
lay rep