Cases2220047/2024

Claimant v The Sports PR Company

24 January 2025Before Employment Judge ScottLondon Centralremote video

Outcome

Claimant succeeds£1,304

Individual claims

Unlawful Deduction from Wagessucceeded

The tribunal found the claimant worked 1-12 March 2024 and was not paid for this period. The respondent failed to identify any contractual or statutory basis for the deduction. This constituted an unlawful deduction from wages under s13 ERA 1996.

Unlawful Deduction from Wagesfailed

For 13-14 March 2024, the tribunal found the claimant's holiday request was not authorised and his absence was unauthorised. The claimant was not ready, willing and able to work, so wages were not 'properly payable' under s13(3) ERA 1996.

Holiday Paysucceeded

The tribunal calculated the claimant accrued 6 days annual leave by 12 March 2024 under the Working Time Regulations 1998, had taken 2 days, leaving 4 days outstanding. The respondent acknowledged holiday was owed but failed to pay. The claimant was entitled to payment in lieu for 4 days untaken accrued holiday at termination.

Facts

The claimant was employed as a Junior Publicist from October 2020 to March 2024. He gave notice in December 2023 with final employment date 14 March 2024. He worked 1-12 March 2024 but was not paid. He requested annual leave for 13-14 March, which was refused, but he did not attend work on those days. The respondent failed to attend the final hearing and had not complied with case management orders. The claimant was represented pro bono by the Free Representation Unit.

Decision

The tribunal found the respondent made unlawful deductions from wages for the period 1-12 March 2024 when the claimant worked but was not paid (£884.36). The claim for unpaid wages for 13-14 March failed as the claimant's absence was unauthorised. The tribunal upheld the holiday pay claim, finding the claimant was entitled to 4 days accrued but untaken holiday (£399.88) plus interest of £19.37, totalling £1,303.61 gross.

Practical note

Employers cannot withhold all wages for a pay period even when alleging breach of contract; and holiday pay calculations must comply with the Working Time Regulations' 5.6 weeks minimum, not just contractual entitlements.

Award breakdown

Holiday pay£400
Arrears of pay£884
Unpaid wages£884
Interest£19

Award equivalent: 2.6 weeks' gross pay

Legal authorities cited

Delaney v Staples (t/a De Montfort Recruitment) [1991] ICR 331Main v SpaDental [2024] EAT 200Attorney General v Barker [2000] 1 FLR 759

Statutes

Working Time Regulations 1998 reg 13ERA 1996 s.24(2)ERA 1996 s.13Working Time Regulations 1998 reg 16Working Time Regulations 1998 reg 30Working Time Regulations 1998 reg 13A

Case details

Case number
2220047/2024
Decision date
24 January 2025
Hearing type
full merits
Hearing days
1
Classification
contested

Respondent

Sector
professional services
Represented
No

Employment details

Role
Junior Publicist
Salary band
£25,000–£30,000
Service
3 years

Claimant representation

Represented
Yes
Rep type
barrister