Cases1401254/2023

Claimant v Royal Mail Group Limited

3 March 2025Before Regional Employment Judge PiraniBristolon papers

Outcome

Claimant fails

Individual claims

Detrimentstruck out

The claims were struck out under rule 38(1)(a) on the basis that they had no reasonable prospect of success. The Supreme Court in Mercer held that section 145A TULRCA, which concerns inducements relating to union membership or activities, does not include industrial action within 'activities of an independent trade union' at 'an appropriate time'. The tribunal found it had no jurisdiction to entertain these claims following binding Supreme Court authority.

Facts

1,885 claimants brought claims under section 145A TULRCA alleging Royal Mail offered unlawful inducements by implementing incentive schemes during November-December 2022 that required employees to work during strike days to receive enhanced payments. The claimants were members of the Communication Workers Union engaged in lawful industrial action during a dispute over pay and terms and conditions. Royal Mail offered the schemes due to operational demands during the Christmas peak period.

Decision

The tribunal struck out all claims under rule 38(1)(a) on the basis they had no reasonable prospect of success. Following the Supreme Court decision in Mercer, the tribunal found it had no jurisdiction to entertain claims under section 145A TULRCA concerning industrial action, as industrial action does not fall within 'activities of an independent trade union' at 'an appropriate time' under Part III of TULRCA.

Practical note

Section 145A TULRCA does not protect employees from inducements relating to participation in lawful industrial action following the Supreme Court decision in Mercer, leaving such claims without domestic legal remedy despite the declaration of incompatibility with Article 11 ECHR.

Legal authorities cited

Mercer [2024] UKSC (Supreme Court)

Statutes

TULRCA s.146TULRCA s.145AHuman Rights Act 1998 s.3Human Rights Act 1998 s.4

Case details

Case number
1401254/2023
Decision date
3 March 2025
Hearing type
strike out
Hearing days
Classification
procedural

Respondent

Sector
logistics
Represented
Yes

Claimant representation

Represented
Yes
Rep type
union