Cases3302740/2024

Claimant v M & M Cosmetics Ltd

15 January 2025Before Employment Judge BeckettWatfordremote video

Outcome

Claimant succeeds

Facts

The claimant was CEO of Afrocenchix Limited from 2010 until it was liquidated in June 2023. Her employment was intended to transfer to the second respondent under TUPE, but this did not occur due to the liquidation. While on maternity leave, she was offered employment by Mr Kalla, though no contract was signed. She received maternity pay, holiday pay, and was asked to perform work. The respondent treated her as an employee, dealing with tax/NI through payroll and engaging HR consultants for a redundancy process.

Decision

The tribunal found that the claimant was an employee of the second respondent despite no signed contract. Applying Ready Mixed Concrete, the tribunal held that the requirements of personal service, control, and remuneration (including expectation of future work) were met. The respondent's conduct in paying maternity/holiday pay, operating payroll, and using grievance procedures demonstrated the employment relationship.

Practical note

An employment relationship can be established through the parties' conduct and treatment of each other, even without a formal written and signed contract, particularly where payments are made through payroll and employment procedures are followed.

Legal authorities cited

Ready Mixed Concrete v Minister of Pensions [1968] 2 QB 497Key2Law (Surrey) LLP v De'Antiquis [2011] EWCA Civ 1567

Statutes

TUPE 2006 s.4Insolvency Act 1986 s.216(3)TUPE 2006 s.8(7)

Case details

Case number
3302740/2024
Decision date
15 January 2025
Hearing type
preliminary
Hearing days
1
Classification
contested

Respondent

Sector
retail
Represented
Yes
Rep type
barrister

Employment details

Role
CEO and Head of Marketing
Salary band
£60,000–£80,000
Service
13 years

Claimant representation

Represented
No