Cases2401355/2024

Claimant v Confident Futures Limited

15 February 2025Before Employment Judge L CowenManchesterremote video

Outcome

Partly successful£6,900

Individual claims

Unfair Dismissalfailed

The tribunal found that the claimant was not an employee of the First Respondent for the purposes of section 230 of the Employment Rights Act 1996. Without an employment relationship, no claim for unfair dismissal could succeed against this respondent.

Unfair Dismissalsucceeded

The tribunal found that the claimant was an employee of the Second Respondent and that the dismissal was unfair. However, a Polkey deduction was applied because the claimant would have been fairly dismissed in any event due to the liquidation of the Second Respondent.

Unlawful Deduction from Wagessucceeded

The tribunal found that the Second Respondent had made an unlawful deduction from the claimant's wages, specifically unpaid holiday pay of £560 for leave accrued between 1 January 2024 and 26 February 2024.

Facts

The claimant brought unfair dismissal claims against two respondents. She was dismissed on 26 February 2024 after approximately two years of service. The Second Respondent went into creditors voluntary liquidation. The tribunal had to determine which entity was her actual employer and whether the dismissal was fair. Neither respondent attended the hearing.

Decision

The tribunal found the claimant was not employed by the First Respondent but was an employee of the Second Respondent. Her unfair dismissal claim against the Second Respondent succeeded, but a Polkey deduction was applied because she would have been fairly dismissed anyway due to the liquidation. She was also awarded unpaid holiday pay of £560.

Practical note

Even where an unfair dismissal claim succeeds, significant Polkey reductions can eliminate future loss where the employee would inevitably have been fairly dismissed, such as in cases of employer insolvency.

Award breakdown

Basic award£2,100
Compensatory award£4,240
Holiday pay£560

Legal authorities cited

Polkey v A E Dayton Services Ltd [1988] ICR 142

Statutes

ERA 1996 s.230

Case details

Case number
2401355/2024
Decision date
15 February 2025
Hearing type
full merits
Hearing days
2
Classification
contested

Respondent

Sector
professional services
Represented
No

Employment details

Service
2 years

Claimant representation

Represented
No