Cases2302792/2024

Claimant v NewsTeam Group Limited

14 February 2025Before Employment Judge HarringtonLondon Southremote video

Outcome

Claimant fails

Individual claims

Unlawful Deduction from Wagesfailed

The tribunal found the claimant was neither an employee nor a worker but a self-employed contractor with a genuine right of substitution. The tribunal therefore had no jurisdiction to hear the claim for unlawful deduction from wages, which requires employee or worker status under s.13 ERA 1996.

Facts

The claimant worked as a newspaper delivery driver from December 2023 to February 2024 under a written contract describing him as a self-employed contractor. He claimed unlawful deduction of £800 from his wages, imposed as a penalty when he took a pre-booked holiday without arranging substitute cover. The written contract contained an express right to use substitutes and stated it was not a contract of employment. The claimant acknowledged understanding these terms and accepted the agreement was not an employment contract.

Decision

The tribunal found the claimant was neither an employee nor a worker but a genuine self-employed contractor. The written contract accurately reflected the parties' agreement and contained an unfettered right of substitution, inconsistent with an obligation of personal performance. As employee or worker status is required to bring claims for unlawful deduction from wages, the tribunal had no jurisdiction and dismissed the claim.

Practical note

A clear, genuine and unfettered right of substitution in a written contract, where the parties' true agreement is reflected in those written terms, will defeat both employee and worker status claims.

Legal authorities cited

Ready Mixed Concrete v Minister of Pensions [1968] 2 QB 497Uber BV v Aslam [2021] UKSC 5Autoclenz Ltd v Belcher [2011] UKSC 41Pimlico Plumbers Ltd v Smith [2017] EWCA Civ 51Ter-berg v Simply Smile Manor House Ltd [2023] EAT 2

Statutes

Employment Rights Act 1996 s.230Employment Rights Act 1996 s.13

Case details

Case number
2302792/2024
Decision date
14 February 2025
Hearing type
preliminary
Hearing days
1
Classification
contested

Respondent

Sector
media
Represented
No
Rep type
in house

Employment details

Role
Newspaper delivery driver
Service
2 months

Claimant representation

Represented
No