Cases2400416/2024

Claimant v North West Ambulance Service NHS Trust

20 February 2025Before Employment Judge Jane CallanManchesterremote video

Outcome

Claimant succeeds£6,022

Individual claims

Unlawful Deduction from Wagessucceeded

The tribunal found that the claimant was promised Band 7 pay from 9 April 2023 by Ms Stangar, who had actual or ostensible authority to agree this. The claimant gave consideration by continuing in the role and not claiming meal break allowances. He was substantially fulfilling the complete Band 7 SPTL role, not just undertaking specific development activities, and therefore Band 7 pay was properly payable. The respondent's later decision to revoke B7 pay was not effective.

Facts

The claimant was a Band 6 paramedic who took up a development SPTL role on 9 January 2023, initially on his existing pay. On 20 April 2023, after three months in the role, his line manager confirmed he would be paid at Band 7 rates from 9 April 2023, consistent with similar roles elsewhere in the Trust. The claimant continued in the role and stopped claiming meal break allowances (to which Band 6 but not Band 7 staff were entitled). In September 2023, management revoked the Band 7 pay decision. The claimant had been substantially fulfilling the complete Band 7 SPTL role, not just undertaking specific development activities.

Decision

The tribunal found the claimant's claim for unlawful deduction of wages succeeded. Ms Stangar had actual or ostensible authority to agree Band 7 pay from 9 April 2023, and the claimant gave consideration by continuing in the role and forgoing allowances. The claimant was performing the complete Band 7 role, contrary to the respondent's Recruitment Policy which stated individuals should not undertake a complete role on an unpaid basis. The agreed sum of £6,021.57 gross was awarded.

Practical note

A manager's confirmation of a pay increase can contractually bind the employer if they have actual or ostensible authority, even if subsequently revoked by senior management.

Award breakdown

Arrears of pay£6,022

Legal authorities cited

Statutes

Employment Rights Act 1996 s.13Employment Rights Act 1996 s.23

Case details

Case number
2400416/2024
Decision date
20 February 2025
Hearing type
full merits
Hearing days
1
Classification
contested

Respondent

Sector
healthcare
Represented
Yes
Rep type
barrister

Employment details

Role
Paramedic (Band 6), undertaking Senior Paramedic Team Leader (SPTL) duties
Service
4 years

Claimant representation

Represented
No