Cases3309376/2023

Claimant v The Station Hotel (Newcastle) Limited

27 January 2025Before Employment Judge K DouseWatfordremote video

Outcome

Claimant fails

Individual claims

Unfair Dismissalfailed

The tribunal found that the claimant was not an employee or worker within the meaning of section 230 ERA 1996. There was no contract between the claimant and the respondent company, no mutuality of obligation (the claimant provided no services to the respondent, only to Kiran Sehgal personally), and the respondent exercised no control over the claimant's work. The tribunal therefore had no jurisdiction to hear the unfair dismissal claim.

Redundancy Payfailed

The tribunal found that the claimant was not an employee of the respondent company. There was no contract of employment, no mutuality of obligation, and no control exercised by the respondent. As employment status is a prerequisite for redundancy pay claims, the tribunal had no jurisdiction.

Breach of Contractfailed

The tribunal found that there was no contract, written or otherwise, between the claimant and the respondent company. The claimant's arrangement was with Kiran Sehgal personally, not the respondent. The respondent's only involvement was facilitating payment via payroll at Arvan Handa's instruction. Without an employment contract, the notice pay claim fails for lack of jurisdiction.

Holiday Payfailed

The tribunal found that the claimant was not a worker within the meaning of the ERA 1996 or Working Time Regulations. There was no contract between the claimant and respondent, and the claimant provided no services to the respondent company. Worker status is required for holiday pay claims under the WTR, so the tribunal had no jurisdiction.

Unlawful Deduction from Wagesfailed

The tribunal found that the claimant was not a worker within the meaning of section 230 ERA 1996. Although the respondent processed the claimant's wages via payroll, this was merely a payment mechanism and did not create an employment or worker relationship. Without worker status, the tribunal had no jurisdiction to hear the arrears of pay claim.

Facts

The claimant worked as a nanny/housekeeper for Kiran Sehgal (the granddaughter of the respondent hotel company's founder) from April 2019. She was interviewed by and took instructions solely from Kiran Sehgal. In October 2019, Arvan Handa (a director and Kiran's father) instructed that the claimant be placed on the respondent's payroll. The claimant was paid via the respondent, had tax deducted, received a pension, and was furloughed during COVID-19. She worked Monday-Friday, 7am-7pm at Kiran Sehgal's home doing household duties. In May 2023, following internal disputes, the respondent stopped paying the claimant, who continued working for Kiran Sehgal and being paid directly by her.

Decision

The tribunal found that the claimant was neither an employee nor a worker of the respondent. There was no contract between them—only an arrangement between the claimant and Kiran Sehgal personally. The claimant provided no services to the respondent company, which exercised no control over her work. The respondent's payroll was merely a payment mechanism. Without the necessary mutuality of obligation, personal service to the respondent, or control by the respondent, all claims were dismissed for lack of jurisdiction.

Practical note

Being placed on a company's payroll and receiving employment-related benefits (tax deductions, pension, furlough) does not automatically create employee or worker status if the individual provides no services to that company and is under the direction and control of a third party.

Legal authorities cited

Ready Mixed Concrete v Minister of Pensions [1968] 2 QB 497Nethermere (St Neots) Ltd v Gardiner [1984] ICR 612Carmichael v National Power plc [1999] ICR 1226Dynasystems for Trade and General Consulting Ltd v Moseley EAT 0091/17Autoclenz Ltd v Belcher [2011] UKSC 41Clark v Harney Westwood and Riegels [2021] IRLR 528Commissioners for HM Revenue and Customs v Professional Game Match Officials Ltd [2024] UKSC 29Uber BV v Aslam [2021] UKSC 5

Statutes

ERA 1996 s.230Working Time Regulations 1998

Case details

Case number
3309376/2023
Decision date
27 January 2025
Hearing type
preliminary
Hearing days
1
Classification
contested

Respondent

Sector
hospitality
Represented
Yes
Rep type
barrister

Employment details

Role
Nanny/Housekeeper
Service
4 years

Claimant representation

Represented
Yes
Rep type
barrister