Cases1303012/2022

Claimant v Homes and Communities Agency

11 February 2024Before Employment Judge Algazy K.C.Midlands Westremote video

Outcome

Other

Individual claims

Breach of Contractwithdrawn

The breach of contract claim was withdrawn on 10 September 2022 after the claimant received advice that it clearly could not proceed on jurisdictional grounds while he remained employed.

Unlawful Deduction from Wageswithdrawn

The unlawful deductions claim was withdrawn on 14 December 2022 as a tactical decision after the claimant received advice that there was a risk it would fail on jurisdictional grounds in the Employment Tribunal, though the claimant maintained the case could be distinguished from relevant authorities.

Facts

The claimant was employed since January 2017 as Head of Public Sector Land on a salary of £83,509. He was on secondment from April 2018 onwards. In 2019 the respondent restructured and introduced a new pay and grading scheme in 2022. The claimant disputed his placement in the new structure and grading. He claimed breach of contract and unlawful deduction of wages relating to a standard pay award for 2020/21. He withdrew the breach of contract claim in September 2022 and the deductions claim in December 2022, reserving the right to pursue claims in civil courts.

Decision

The tribunal refused both the respondent's application to dismiss the withdrawn claims and its application for costs. The tribunal found the claimant had a legitimate reason to reserve his right to bring claims elsewhere and that dismissal would not be in the interests of justice. On costs, the tribunal found the respondent had not established that the claimant's conduct was unreasonable or vexatious, and declined to exercise discretion to award costs even if jurisdiction had been engaged.

Practical note

Employment tribunals should not act as gatekeepers to prevent claimants from pursuing withdrawn claims in other forums, and withdrawing claims after taking legal advice does not constitute unreasonable conduct justifying costs, even if done shortly before a hearing.

Legal authorities cited

Yerrakalva v Barnsley Metropolitan Borough Council [2012] ICR 420Radia v Jefferies International [2020] IRLR 431Gee v Shell UK Ltd [2003] IRLR 82McPherson v BNP Paribas [2004] ICR 1398National Oilwell Varco (UK) Ltd v Van de Ruit UKEATS/0006/14/JWHaydar v Pennine Acute NHS Trust UKEAT/0141/1Kingston Upon Hull City Council v Schofield UKEAT/0616/1Coors Brewers Ltd v Adcock [2007] ICR 983

Statutes

Employment Tribunals Rules of Procedure 2013 Rule 52Employment Tribunals Rules of Procedure 2013 Rule 76Employment Rights Act 1996 Part II

Case details

Case number
1303012/2022
Decision date
11 February 2024
Hearing type
costs
Hearing days
3
Classification
procedural

Respondent

Sector
public sector
Represented
Yes
Rep type
barrister

Employment details

Role
Head of Public Sector Land
Salary band
£80,000–£100,000

Claimant representation

Represented
Yes
Rep type
barrister