Cases6008605/2024

Claimant v Lancashire and South Cumbria NHS Foundation Trust

28 February 2025Before Employment Judge FicklinManchesterin person

Outcome

Claimant fails

Individual claims

Unlawful Deduction from Wagesfailed

The tribunal found that the respondent was authorised and required to make the deductions in compliance with an Attachment of Earnings Order issued under the Council Tax Regulations 1992. The deductions were made under statutory provisions as per ERA 1996 s.13(1)(a) and s.14, which expressly exempts deductions required by statute to be paid to a public authority. The claimant's arguments that the order was invalid and that she was not liable for Council Tax were misconceived and outside the tribunal's jurisdiction.

Facts

The claimant, an NHS mental health nurse, had £744.59 deducted from her wages by her employer in February and March 2024 pursuant to an Attachment of Earnings Order issued under Council Tax enforcement regulations. The Order stemmed from a Liability Order made by Barrow-in-Furness Magistrates Court in October 2022 for unpaid Council Tax owed to Westmorland and Furness Council. The claimant argued the deductions were unlawful, contending that the Liability Order was invalid, that she was not liable for Council Tax, and that the enforcement processes violated constitutional law and Magna Carta.

Decision

The tribunal dismissed the claim, finding that the respondent was legally required to make the deductions under the Council Tax Regulations 1992 and that such statutory deductions are expressly exempted from the prohibition on unauthorised deductions under sections 13 and 14 of the Employment Rights Act 1996. The claimant's arguments about the validity of the Liability Order and her liability for Council Tax were misconceived and, in any event, outside the Employment Tribunal's jurisdiction.

Practical note

Employment Tribunals have no jurisdiction to challenge the validity of Attachment of Earnings Orders or Liability Orders made under Council Tax enforcement regulations; employers are required by statute to comply with such orders and deductions made pursuant to them are lawful under ERA 1996.

Legal authorities cited

Leighton v Bristow & Sutor [2024] RA 65Agarwal v Cardiff University & Another [2019] ICR 433Kofa, R (On the Application Of) v Oldham Metropolitan Bolton Council [2024] EWHC 685 (Admin)

Statutes

Council Tax (Administration and Enforcement) Regulations 1992 reg.37ERA 1996 s.14ERA 1996 s.13Tribunals, Courts and Enforcement Act 2007 sch.12 para.66Council Tax (Administration and Enforcement) Regulations 1992 reg.39

Case details

Case number
6008605/2024
Decision date
28 February 2025
Hearing type
full merits
Hearing days
1
Classification
contested

Respondent

Sector
healthcare
Represented
Yes
Rep type
barrister

Employment details

Role
Primary Care mental health nurse

Claimant representation

Represented
No