Cases4100541/2024

Claimant v Glam Candy UK Limited

8 November 2024Before Employment Judge E MannionScotlandin person

Outcome

Claimant succeeds£51,644

Individual claims

Unfair Dismissalsucceeded

The respondent conceded that the redundancy process outlined in the ET3 was a sham. No genuine redundancy situation existed, no consultation took place, and the claimant was not fairly selected. The respondent provided no alternative fair reason for dismissal under Section 98. In the absence of a fair reason, the tribunal found the dismissal on 4 December 2023 was unfair in law.

Unlawful Deduction from Wagessucceeded

The claimant was employed on 1 and 4 December 2023, the only working days before her dismissal. She was not paid for these two days. The tribunal ordered payment of £307.69 gross for these unpaid days.

Breach of Contractsucceeded

The claimant's contract entitled her to three months' notice. She was not paid notice pay on termination. Based on her annual salary of £40,000, the tribunal ordered payment of £10,000 gross representing three months' contractual notice pay.

Holiday Paysucceeded

The tribunal found the claimant had taken only 6 working days of holiday in 2023 (the Val D'Isere trip). She was entitled to 25 days per year, leaving 19 days accrued but untaken annual leave. The tribunal ordered payment of £2,923.15 gross for accrued untaken holiday.

Facts

The claimant co-founded a beauty education business in 2011 and was majority shareholder until June 2023 when she sold her shares to Mr Thompson. She continued working in marketing. In December 2023, Mr Thompson removed her as director and sent a sham redundancy letter terminating her employment. The respondent argued she was never an employee, only a director/shareholder. The tribunal heard evidence about her contract of employment issued in 2020, her payment through PAYE, her regular hours worked, her integration into the business, and the control exercised over her by the respondent post-sale of shares.

Decision

The tribunal found the claimant was an employee throughout her service from 2011 to dismissal in December 2023, including the period when she was majority shareholder. The respondent failed to prove the contract of employment did not reflect the true relationship. The tribunal found the irreducible minimum of control, personal service, and mutuality of obligation existed. The dismissal was unfair as the respondent conceded the redundancy was a sham and provided no other fair reason under s.98 ERA 1996. The claimant was awarded basic and compensatory awards, notice pay, unpaid wages, and accrued holiday pay totalling £51,643.84.

Practical note

A majority shareholder and director can simultaneously be an employee if the contract, PAYE payment, working arrangements, and conduct are consistent with employment status, and control passes to another after share sale.

Award breakdown

Basic award£7,716
Compensatory award£30,347
Notice pay£10,000
Holiday pay£2,923
Unpaid wages£308
Loss of statutory rights£350

Award equivalent: 67.1 weeks' gross pay

Legal authorities cited

Ready Mixed Concrete v Minister of Pensions [1968] 2 QB 497White v Troutbeck SA [2013] IRLR 949Pimlico Plumbers Ltd v Smith [2017] EWCA Civ 51Stevedoring & Haulage Services Ltd v Fuller [2001] IRLR 627Hall (Inspector of Taxes) v Lorimer [1994] ICR 218Clark v Clark Construction Initiatives Ltd [2008] ICR 635Secretary of State for Employment v John Woodrow and Sons (Builders) Ltd [1983] ICR 582Norton Tool Ltd v Tewson [1972] ICR 501

Statutes

ERA 1996 s.119ERA 1996 s.123ERA 1996 s.98ERA 1996 s.230ERA 1996 s.118

Case details

Case number
4100541/2024
Decision date
8 November 2024
Hearing type
full merits
Hearing days
3
Classification
contested

Respondent

Sector
education
Represented
Yes
Rep type
lay rep

Employment details

Role
Marketing role / senior management
Salary band
£40,000–£50,000
Service
12 years

Claimant representation

Represented
No