Cases1405883/2023

Claimant v Ms Charity Earnshaw (Trading as Charity Earnshaw Home Care Agency)

31 May 2024Before Employment Judge N J RoperSouth West (based on East Devon reference)remote video

Outcome

Claimant succeeds£3,749

Individual claims

Unlawful Deduction from Wagessucceeded

The tribunal found the respondent was not entitled to deduct unspecified 'office administration fees' of £500 or training fees of £2,500. There was no evidence the claimant agreed to such deductions or that fees were incurred specifically for him. The respondent deducted the claimant's entire wages for August 2023 (£1,795.54) and September 2023 (£788.88), totalling £2,584.42. After deducting the conceded £600 for solicitor's fees, unlawful deductions totalled £1,984.42.

Facts

The claimant worked as a care worker for the respondent's home care agency from April 2022 to September 2023. When he resigned in August 2023, the respondent withheld his entire wages for August (£1,795.54) and September (£788.88) claiming she was entitled to recoup £6,600 for training costs, lawyer fees, and office administration. The claimant raised a formal grievance on 30 August 2023 which the respondent failed to address. The claimant's contract of employment did not specify his rate of pay, referring instead to an employee handbook he never received.

Decision

The tribunal found the respondent made unlawful deductions totalling £1,984.42 (after deducting £600 in agreed solicitor's fees). The respondent failed to provide evidence that the claimant agreed to the deductions or that training fees were incurred specifically for him. The tribunal awarded a 20% ACAS uplift for failure to respond to the grievance, two weeks' pay for defective employment particulars, and £250 for inaccurate payslips, totalling £3,749.26.

Practical note

Employers cannot lawfully deduct training costs or administrative fees from final wages without clear contractual authority and evidence that costs were specifically incurred for that employee; failure to respond to grievances will attract ACAS uplifts.

Award breakdown

Unpaid wages£1,984

Adjustments

ACAS uplift+20%

The respondent failed to respond to the claimant's formal written grievance dated 30 August 2023. The tribunal applied a 20% uplift (£396.88) to the unlawful deductions award for this failure to follow the ACAS Code on Disciplinary and Grievance Procedures.

Legal authorities cited

Statutes

ERA 1996 s.13TULRCA 1992 s.207AERA 1996 s.1ERA 1996 s.12(4)Employment Act 2002 s.38

Case details

Case number
1405883/2023
Decision date
31 May 2024
Hearing type
full merits
Hearing days
1
Classification
contested

Employment details

Role
care worker
Service
1 years

Claimant representation

Represented
Yes
Rep type
barrister