Cases1300206/2024

Claimant v K9 Stata Security Ltd

16 August 2024Before Employment Judge N. ClarkeBirminghamhybrid

Outcome

Claimant fails

Individual claims

Unlawful Deduction from Wagesfailed

The tribunal found the claimant was a worker under s.230(3) ERA 1996, but he failed to prove unlawful deductions. Despite claiming £1000 was deducted from monthly invoices totalling £30,000, the claimant only produced five invoices during the entire period. Three of those were paid in full. The evidence showed a complicated payment pattern including advance payments and loans. The tribunal found it impossible from the incomplete evidence to determine exactly what was invoiced and paid, and concluded the claimant had not proved on the balance of probabilities that he had been underpaid.

Facts

The claimant worked as a security guard for the respondent from April 2021, invoicing monthly in arrears for work done. He claimed the respondent deducted £1000 from each monthly invoice, totalling around £30,000 over 30 months. The respondent argued the claimant was not a worker and denied any underpayments. The evidence consisted of incomplete bank statements, invoices and messages from both parties, showing a complicated payment pattern including advance payments and loans.

Decision

The tribunal found the claimant was a worker under s.230(3) ERA 1996 because he had no meaningful power of delegation and was not running his own business. However, the unlawful deduction claim failed because the claimant failed to prove his case. He produced only five invoices, three of which were paid in full, and failed to produce a proper schedule of loss despite being given opportunities to do so. The incomplete and contradictory evidence meant the tribunal could not determine on the balance of probabilities that any underpayments had occurred.

Practical note

A claimant must prove unlawful deductions with clear documentary evidence showing what was invoiced and what was paid, particularly where the payment pattern is complicated and includes advances or loans — inadequate record-keeping will result in failure of the claim even where worker status is established.

Legal authorities cited

Autoclenz Ltd v Belcher [2011] UKSC 41Uber BV v Aslam [2021] UKSC 5Byrne Brothers (Formwork) Ltd v Baird [2002] ICR 667Ready Mixed Concrete (South East) Ltd v Minister of Pensions [1968] 1 All ER 433Redrow Homes (Yorkshire) Ltd v Wright [2004] ICR 1126

Statutes

ERA 1996 s.13ERA 1996 s.230(3)

Case details

Case number
1300206/2024
Decision date
16 August 2024
Hearing type
full merits
Hearing days
1
Classification
contested

Respondent

Sector
professional services
Represented
Yes
Rep type
solicitor

Employment details

Role
security guard
Service
3 years

Claimant representation

Represented
No