Cases6019186/2024

Claimant v Revolute Limited

Outcome

Claimant fails

Individual claims

Automatic Unfair Dismissalfailed

The tribunal found it was not 'likely' the claimant could establish she was an employee of any respondent, a prerequisite for automatic unfair dismissal. The tribunal also found her disclosures unlikely to qualify as protected disclosures in the public interest, as they related solely to her own treatment. The application for interim relief was therefore refused.

Whistleblowingfailed

The tribunal found the claimant's disclosures relating to data protection and Equality Act breaches did not meet the threshold of being reasonably believed to be in the public interest, as all complaints related to her own treatment. The tribunal assessed her prospects of showing qualifying disclosures fell below the 'likely' threshold required for interim relief.

Facts

The claimant was a temporary worker supplied through twentyAI Limited to Revolute Limited under a Statement of Work running from November 2024 to February 2025. She incorporated her own company, Zoogla Limited, in October 2024 which contracted with twentyAI to supply her services. She brought automatic unfair dismissal and whistleblowing claims, seeking interim relief. She made disclosures about alleged data protection and Equality Act breaches relating to her own treatment.

Decision

The tribunal refused the application for interim relief, finding the claimant did not have a 'pretty good chance' of establishing she was an employee of any respondent, given the typical agency worker arrangement and the necessity test for implying a contract. The tribunal also found her disclosures unlikely to qualify as protected disclosures in the public interest, as they related solely to her personal treatment. The reconsideration application was dismissed as having no reasonable prospects of success and was found to be totally without merit.

Practical note

Interim relief applications in whistleblowing cases require a high threshold showing employee status, public interest element in disclosures, and strong causal link; agency worker arrangements will rarely meet the necessity test for implied employment contracts.

Legal authorities cited

Dacas v Brook Street Bureau (UK) Ltd [2004] ICR 1437Uber BV v Aslam [2021] UKSC 5Liddington v 2Gether NHS Foundation Trust EAT/0002/16Lindsay v Ironsides Ray and Vials [1994] ICR 384Flint v Eastern Electricity Board [1975] ICR 395Ministry of Justice v Burton and Anor [2016] EWCA Civ 714Chesterton Global Ltd & Anor v Nurmohamed & Anor [2017] EWCA Civ 979Raja v SS for Justice UKEAT/0364/09/CEATaplin v C Shippam Ltd [1978] ICR 1068Dandpat v University of Bath UKEAT/0408/09London City Airport v Chacko [2013] IRLR 61James v Greenwich London Borough Council [2008] ICR 545Tilson v Alstom Transport [2011] IRLR 169

Statutes

ERA 1996 s.128ERA 1996 s.94ERA 1996 s.103AERA 1996 s.230ERA 1996 s.43BERA 1996 s.43AERA 1996 s.129

Case details

Case number
6019186/2024
Decision date
21 February 2025
Hearing type
reconsideration
Hearing days
1
Classification
procedural

Respondent

Sector
financial services
Represented
Yes
Rep type
barrister

Employment details

Role
temporary worker
Service
3 months

Claimant representation

Represented
No