Cases2600195/2024

Claimant v SS Retail NH Ltd

23 January 2025Before Employment Judge MuzafferNottinghamin person

Outcome

Claimant fails

Individual claims

Unlawful Deduction from Wagesstruck out

The claim was dismissed because it was not presented within the three-month time limit required by section 23(2) of the Employment Rights Act 1996. The tribunal found it was reasonably practicable for the claimant to have presented the claim in time, and therefore no jurisdiction existed to consider it.

Facts

Mrs Dudley brought a claim for unauthorised deduction of wages against her former employer, a retail company. The respondent did not attend the hearing. The claim was presented outside the three-month statutory time limit for such claims under section 23(2) of the Employment Rights Act 1996.

Decision

The tribunal dismissed the claim on jurisdictional grounds, finding that it was reasonably practicable for the claimant to have presented her claim within the statutory time limit. As the claim was presented out of time and the test for extension was not met, the tribunal had no jurisdiction to consider it.

Practical note

Unrepresented claimants must strictly observe the three-month time limit for wage deduction claims, as tribunals have no jurisdiction to hear out-of-time claims unless it was not reasonably practicable to present them in time.

Legal authorities cited

Statutes

ERA 1996 s.13ERA 1996 s.23(2)ERA 1996 s.23(4)

Case details

Case number
2600195/2024
Decision date
23 January 2025
Hearing type
preliminary
Hearing days
1
Classification
contested

Respondent

Sector
retail
Represented
No

Claimant representation

Represented
No