Cases3201623/2024

Claimant v Diamond Hangar Limited

13 February 2025Before Employment Judge WilkinsonEast Londonremote video

Outcome

Claimant succeeds

Individual claims

Constructive Dismissalsucceeded

The tribunal found that the respondent's failure to pay the claimant promptly or at all following 4 March 2024 was a fundamental breach of contract and a breach of the implied term of trust and confidence. The claimant resigned on 4 June 2024 in response to this repudiatory breach, having waited two months without payment or explanation. The dismissal was unfair as the claimant did not engage in misconduct and the suspension was said to be temporary for business reorganisation.

Wrongful Dismissalsucceeded

The tribunal found the claimant was entitled to six months' notice pay in a lump sum within seven days as per the contract. The claimant did not receive this notice pay. The claim for wrongful dismissal succeeded and will be addressed at the remedy hearing.

Unlawful Deduction from Wagessucceeded

The tribunal found that the respondent made unauthorised deductions from the claimant's wages in the period 1 April 2024 to 4 June 2024 inclusive. The claimant was entitled to monthly payments of £6,000 but did not receive payment for one month during this period, despite repeated requests.

Facts

The claimant worked for the respondent from August 2018 as Director of Administration at a hangar facility at Stansted Airport, paid £6,000 per month. Although he signed a 'service agreement' describing him as a contractor, the reality was that he worked under the control and supervision of the owner Prince Eze, was paid a salary regardless of work done, worked set hours on the respondent's premises, and was integral to the business. On 1 March 2024 he was suspended pending a business reorganisation. He was paid once in April 2024 but thereafter the respondent failed to pay him despite repeated requests and assurances the suspension was temporary. He resigned on 4 June 2024 citing non-payment. The respondent alleged various acts of misconduct and mismanagement which the tribunal found were not proven.

Decision

The tribunal found that despite the written contract labelling the claimant as a contractor, the reality of the relationship was that he was an employee under a contract of employment. The respondent's failure to pay the claimant from March 2024 onwards was a fundamental breach of contract and breach of the implied term of trust and confidence. The claimant was constructively unfairly dismissed when he resigned on 4 June 2024. The tribunal rejected the respondent's allegations of misconduct as unproven and found no Polkey reduction or contributory fault. The claims for constructive unfair dismissal, wrongful dismissal and unlawful deduction of wages all succeeded. Remedy to be determined at a further hearing.

Practical note

Written contract terms describing a relationship as contractor/client are not determinative if the reality of the working relationship demonstrates the hallmarks of employment: control, integration, payment of a salary regardless of work done, and set hours at the employer's premises. Suspension followed by non-payment without explanation can amount to a fundamental breach entitling the employee to resign and claim constructive dismissal.

Legal authorities cited

Boston Deep Sea Fishing and Ice Co v Ansell [1888] 39 Ch D 339Ready Mixed Concrete v Minister of Pensions [1968] 2 QB 497Williams v Compair Maxam [1982] ICR 156Sainsbury's Supermarkets Ltd v Hitt [2003] ICR 111BHS v Burchell [1978] IRLR 379W Devis and Sons Ltd v Atkins [1977] ICR 662Polkey v A E Dayton Services Ltd [1988] ICR 142Western Excavating v Sharp [1978] ICR 221Nethermere (St Neots) Ltd v Gardiner [1984] ICR 612Hall v Lorimer [1994] 1 WLR 209

Statutes

Employment Rights Act 1996 s.95Employment Rights Act 1996 s.230Employment Rights Act 1996 s.139Employment Rights Act 1996 s.123(6)Employment Rights Act 1996 s.94Employment Rights Act 1996 s.122(2)Employment Rights Act 1996 s.111Employment Rights Act 1996 s.98

Case details

Case number
3201623/2024
Decision date
13 February 2025
Hearing type
full merits
Hearing days
2
Classification
contested

Respondent

Sector
real estate
Represented
Yes
Rep type
barrister

Employment details

Role
Director of Administration
Salary band
£60,000–£80,000
Service
6 years

Claimant representation

Represented
Yes
Rep type
solicitor