Cases2214125/2023

Claimant v The Kingdom of Eswatini

27 January 2025Before Employment Judge L BrownLondon Centralremote video

Outcome

Other

Individual claims

Unfair Dismissalnot determined

Preliminary hearing determined only the issue of state immunity. The claim was found not to be barred by state immunity and can proceed to a full hearing on the merits.

Wrongful Dismissalnot determined

Preliminary hearing determined only the issue of state immunity. The claim was found not to be barred by state immunity and can proceed to a full hearing on the merits.

Direct Discrimination(religion)not determined

Claimant alleged race discrimination as a Jewish person. Preliminary hearing determined only the issue of state immunity. The claim was found not to be barred by state immunity and can proceed to a full hearing on the merits.

Breach of Contractnot determined

Claim for failure to pay notice pay. Preliminary hearing determined only the issue of state immunity. The claim was found not to be barred by state immunity and can proceed to a full hearing on the merits.

Unlawful Deduction from Wagesnot determined

Claim relating to overtime pay. Preliminary hearing determined only the issue of state immunity. The claim was found not to be barred by state immunity and can proceed to a full hearing on the merits.

Holiday Paynot determined

Claimant stated in grounds of complaint that he had not been paid holiday pay. Preliminary hearing determined only the issue of state immunity. The claim was found not to be barred by state immunity and can proceed to a full hearing on the merits.

Facts

Claimant was employed as chauffeur for the High Commission of the Kingdom of Eswatini from September 2022 to June 2023. He primarily drove the High Commissioner, diplomatic staff, government ministers and members of the Royal Family. He occasionally delivered files within the High Commission, acted as receptionist, and attempted to promote his business contacts to the Mission for potential commercial deals, though these overtures were largely rebuffed by the Mission.

Decision

The tribunal found that the claimant's employment was not an exercise of sovereign authority and his claim is not barred by state immunity. The claimant's functions as a chauffeur and occasional administrative assistant were not sufficiently close to the governmental functions of the Mission. His driving functions were purely collateral to the Mission's sovereign work, and his attempted business promotion activities were personal initiatives not requested or endorsed by the Mission.

Practical note

Employment as a chauffeur at a diplomatic mission, even when driving senior diplomats and royalty, is not inherently an exercise of sovereign authority unless the employee's functions are sufficiently close to the governmental work of the mission, which requires more than incidental contact with confidential matters or important passengers.

Legal authorities cited

Benkharbouche v Secretary of State for Foreign and Commonwealth Affairs [2018] IRLR 123The Royal Embassy of Saudi Arabia (Cultural Bureau) v Alhayali [2023] EAT 149Webster & Wright v USA [2022] EAT 92Kingdom of Spain v Lorenzo [2024] EWCA Civ 1602Governor of Pitcairn and Associated Islands v Sutton (1994) 104 ILR 508Benkharbouche v Secretary of State for Foreign and Commonwealth Affairs [2018] IRLR 123The Royal Embassy of Saudi Arabia (Cultural Bureau) v Alhayali [2023] EAT 149Webster & Wright v USA [2022] EAT 92Kingdom of Spain v Lorenzo [2024] EWCA Civ 1602Governor of Pitcairn and Associated Islands v Sutton (1994) 104 ILR 508

Statutes

State Immunity Act 1978 s.1State Immunity Act 1978 s.4State Immunity Act 1978 s.16State Immunity Act 1978 (Remedial) Order 2023Vienna Convention on Diplomatic Relations Article 3State Immunity Act 1978 s.1State Immunity Act 1978 s.4State Immunity Act 1978 s.16State Immunity Act 1978 (Remedial) Order 2023Vienna Convention on Diplomatic Relations Article 3

Case details

Case number
2214125/2023
Decision date
27 January 2025
Hearing type
preliminary
Hearing days
1
Classification
contested

Respondent

Sector
public sector
Represented
Yes
Rep type
barrister

Employment details

Role
Chauffeur
Salary band
£30,000–£40,000
Service
9 months

Claimant representation

Represented
Yes
Rep type
barrister