Cases2402521/2024

Claimant v Oxford Residential Limited

6 November 2024Before Employment Judge Phil AllenManchesterremote video

Outcome

Claimant succeeds£29,808

Individual claims

Unfair Dismissalsucceeded

The claimant was dismissed in a telephone call on 8 December 2023 with no process followed. The respondent failed to file a response and could not show a fair reason for dismissal. Applying section 98(4) ERA 1996, the dismissal was unfair as no fair procedure was followed.

Unlawful Deduction from Wagessucceeded

The claimant was due commission of £26,736 based on sales he managed. The tribunal found it was an implied term by custom and practice that commission was paid on exchange not completion, as the claimant had previously been paid on that basis. The respondent's director Paul Preston confirmed by email that the amount claimed was 'all correct'. The respondent had no legal authorisation to withhold these sums.

Facts

The claimant worked for the respondent from August 2020 to December 2023 in a commission-based role. He was dismissed without warning in a telephone call on 8 December 2023. His contract entitled him to 1% commission on distribution channel sales but did not specify whether this was payable on exchange or completion. The respondent failed to pay him £26,736 in commission he claimed was due, which the respondent's director initially confirmed was correct by email. The respondent failed to file a response to the tribunal claim.

Decision

The tribunal found the dismissal was unfair as no fair procedure was followed and the respondent failed to show a fair reason. The tribunal also found the respondent had made an unauthorised deduction from wages by failing to pay the commission. Based on the claimant's evidence of past practice and the director's email confirmation, the tribunal found it was an implied term that commission was payable on exchange, not completion, and awarded the full amount claimed.

Practical note

Employers must clearly specify commission payment terms in contracts, as tribunals may find implied terms based on custom and practice, particularly where the employer fails to participate in proceedings or file a defence.

Award breakdown

Basic award£2,572
Compensatory award£500
Unpaid wages£26,736
Loss of statutory rights£500

Legal authorities cited

Statutes

ERA 1996 s.111ERA 1996 s.119ERA 1996 s.123ERA 1996 s.94ERA 1996 s.13ERA 1996 s.23ERA 1996 s.27(1)(a)ERA 1996 s.124ERA 1996 s.98

Case details

Case number
2402521/2024
Decision date
6 November 2024
Hearing type
full merits
Hearing days
1
Classification
contested

Respondent

Sector
real estate
Represented
No

Employment details

Service
3 years

Claimant representation

Represented
No