Cases1400721/2024

Claimant v Ecoserv FM Group Limited

28 February 2025Before Employment Judge Sangeron papers

Outcome

Claimant succeeds

Facts

The Claimant brought claims against the Respondent, which filed a response in May 2024. A final hearing listed for September 2024 was postponed at the Claimant's request. In January 2025, the Respondent's representative informed the tribunal the company was insolvent and they were no longer instructed. The Respondent then ceased all communication, failed to provide witness statements or documents, and did not attend the final hearing on 21 February 2025. Judgment was entered in favour of the Claimant, who then applied for costs.

Decision

The tribunal awarded costs of £3,028.90 (50% of the costs claimed) against the Respondent under Rule 74(2)(a) for unreasonable conduct and Rule 74(3) for breaching case management orders. While the Claimant also breached some orders, the Respondent's complete failure to engage from January 2025 onwards, including failing to file evidence and attend the hearing, warranted a costs award. The tribunal rejected the argument that the response had no reasonable prospect of success.

Practical note

Even where a respondent becomes insolvent and ceases engagement, tribunals will award costs for unreasonable conduct and breach of orders, though the amount may be reduced where the claimant has also failed to comply with directions.

Legal authorities cited

Gee v Shell UK Ltd [2003] IRLR 82Oni v Unison ICR D17Millin v Capsticks Solicitors [2014] UKEAT/0093/14QDOS Consulting Ltd v Swanson UKEAT/0495/11McPherson v BNP Paribas [2004] ICR 1398Raggett v John Lewis [2012] IRLR 911Sunuva v Martin UKEAT/0174/17Lodwick v Southwark [2004] ICR 844Yerrakalva v Barnsley Metropolitan Borough Council [2012] ICR 420

Statutes

Employment Tribunal Procedure Rules 2024 rule 74(3)Employment Tribunal Procedure Rules 2024 rule 74(2)(a)

Case details

Case number
1400721/2024
Decision date
28 February 2025
Hearing type
costs
Hearing days
Classification
procedural

Respondent

Sector
professional services
Represented
No
Rep type
self

Claimant representation

Represented
No