Cases2216662/2024

Claimant v Metlife Europe Services Limited

10 January 2025Before Employment Judge SE LangridgeLondon Centralremote video

Outcome

Claimant fails

Individual claims

Equal Pay(race)struck out

Claim struck out as out of time (3 month period expired 6 September 2023) and amounted to bare assertion without particulars. No facts pleaded from which tribunal could conclude discrimination. Claim also compromised by settlement agreement entered into 7 June 2023.

Equal Pay(sex)struck out

Claim struck out as out of time (limitation expired 6 September 2023) and lacked any particulars. Claimant provided no facts to support alleged pay inequality. Claim also compromised by settlement agreement which waived all potential claims arising from employment.

Direct Discrimination(pregnancy)struck out

Claim based on being investigated during maternity leave struck out as bare assertion without facts capable of shifting burden of proof under s136 Equality Act. Respondent's evidence showed innocent explanation for timing. Claim out of time and compromised by settlement agreement.

Unfair Dismissalstruck out

Claim struck out as having no reasonable prospect of success. Employment ended by mutual agreement through settlement agreement on 7 June 2023, so no dismissal occurred. Claim also out of time (limitation expired 6 September 2023) and compromised by settlement agreement.

Breach of Contractstruck out

Original breach of contract claim relating to failure to follow disciplinary procedure struck out. Disciplinary procedure was non-contractual and employment ended by settlement agreement to avoid disciplinary process. Claim out of time and compromised by settlement agreement. Proposed amendment to add breach of settlement agreement claim refused.

Facts

Claimant was employed as Assistant General Counsel from July 2019 until termination by settlement agreement on 7 June 2023. She went on maternity leave in February 2023 and gave birth in late February. In March 2023 respondent began investigating her personal use of company credit card during maternity leave. Investigation led to settlement negotiations in May 2023. Settlement agreement signed 7 June 2023 provided for severance payments exceeding £90,000 including enhanced maternity pay. Due to administrative error, £2,831.01 of maternity pay was underpaid on 24 June 2023 and corrected on 24 November 2023. Claimant brought tribunal claims in March 2024 seeking to set aside settlement agreement based on late payment.

Decision

Tribunal struck out all claims under Rule 37 as abuse of process and having no reasonable prospect of success. Claims were compromised by valid settlement agreement. Claimant's application to amend to add new breach of contract claims refused as out of time and lacking merit. Tribunal had no jurisdiction over alleged breach of settlement agreement as claim arose after termination date under 1994 Order Article 3(c). All claims significantly out of time with no basis for extension.

Practical note

Settlement agreements properly executed under statutory requirements create binding compromises that cannot be reopened through tribunal claims based on subsequent administrative errors in payment, even during protected maternity period, absent fundamental breach or valid grounds to set aside the agreement.

Legal authorities cited

Madarassy v Nomura International Plc [2007] ICR 867Miller Bros & FP Butler Ltd v Johnston [2002] ICR 744Rock-it Cargo Ltd v Green [1997] IRLR 581Sweeney v Peninsula Business Services [2004] IRLR 49Vaughan v Modality Partnership [2021] ICR 535Cox v Adecco UKEAT/0339/ATJamu v Asda UKEAT/0221/15/DAChandock v Tirkey [2015] ICR 527Ezsias v North Glamorgan NHS Trust [2007] ICR 1126Olatunde v Viewber Ltd [2023] EAT 158TGWU v Safeway Stores UKEAT/0092/07Abercrombie v Aga Rangemaster Ltd [2013] ICR 606Craig v Abellio [2022] EAT 43Gallilee v Commissioner of Police of the Metropolis UKEAT/0207/16/RNBennett v Southwark London Borough Council [2002] ICR 881

Statutes

Equality Act 2010 s.147Employment Rights Act 1996 s.203Equality Act 2010 s.108Equality Act 2010 s.136Employment Rights Act 1996 s.111Equality Act 2010 s.123Employment Tribunal Extension of Jurisdiction (England & Wales) Order 1994 Article 3(c)Employment Tribunal Extension of Jurisdiction (England & Wales) Order 1994 Article 7

Case details

Case number
2216662/2024
Decision date
10 January 2025
Hearing type
preliminary
Hearing days
2
Classification
contested

Respondent

Sector
financial services
Represented
Yes
Rep type
barrister

Employment details

Role
Assistant General Counsel
Service
4 years

Claimant representation

Represented
No