“69 The question whether such a relationship exists must be answered in each particular case having regard to all the factors and circumstances by which the relationship between the parties is characterised.”
“What the Courts must essentially try to do here, it seems to me, is to determine whether the essence of the relationship is that of a worker or somebody who is employed, albeit in a small way, in a business undertaking.”
“50 .I would agree that this will often assist in providing the answer, but the difficult cases are where, as in this case, the putative worker does not in fact market his services at all, nor act for any other customer even although Mrs James is not barred by her contract from so doing. In some cases the business is effectively created by the contract.”
“Drawing that distinction in any particular case will involve all or most of the same considerations as arise in drawing the distinction between a contract of service and a contract for services – but with the boundary pushed further in the putative worker's favour. It may, for example, be relevant to assess the degree of control exercised by the putative employer, the exclusivity of the engagement and its typical duration, the method of payment, what equipment the putative worker supplies, the level of risk undertaken etc. The basic effect of limb (b) is, so to speak, to lower the pass-mark, so that cases which failed to reach the mark necessary to qualify for protection as employees might nevertheless do so as workers." 106. In construing contracts similar to that in the instant case, I bear in mind the principles set out in Autoclenz v Belcher[2011] ICR 1157 . The Supreme Court approved the Judgment of Elias J in Consistent Group v Kalwak[2007] IRLR 560 in which Elias J said this, at paragraph 57: “The concern to which tribunals must be alive is that armies of lawyers will simply place substitution clauses, or clauses denying any obligation to accept or provide work in employment contracts, as a matter of form, even where such terms do not begin to reflect the real relationship. Peter Gibson LJ was alive to the problem. He said this (p 697): ‘ Of course, it is important that the industrial tribunal should be alert in this area of the law to look at the reality of any obligations. If the obligation is a sham, it will want to say so.’ In the Supreme Court the Judgment of Smith LJ in Firthglow Ltd (t/a Protectacoat) v Szilagyi[2009] ICR 835 was approved. Smith LJ made clear, having regard to earlier authorities, that the court had to consider whether or not the words of the written contract represented the true intentions or expectations, not only at the inception of the contract but, if appropriate, as time goes by. 107. She continued at paragraph 52: “52. I regret that that short paragraph [ie para 51] requires some clarification in that my reference to 'as time goes by' is capable of misunderstanding. What I wished to say was that the court or tribunal must consider whether or not the words of the written contract represent the true intentions or expectations of the parties (and therefore their implied agreement and contractual obligations), not only at the inception of the contract but at any later stage where the evidence shows that the parties have expressly or impliedly varied the agreement between them. 53. In my judgment the true position, consistent with Tanton , Kalwak and Szilagyi, is that where there is a dispute as to the genuineness of a written term in a contract, the focus of the enquiry must be to discover the actual legal obligations of the parties. To carry out that exercise, the tribunal will have to examine all the relevant evidence. That will, of course, include the written term itself, read in the context of the whole agreement. It will also include evidence of how the parties conducted themselves in practice and what their expectations of each other were. Evidence of how the parties conducted themselves in practice may be so persuasive that the tribunal can draw an inference that that practice reflects the true obligations of the parties. But the mere fact that the parties conducted themselves in a particular way does not of itself mean that that conduct accurately reflects the legal rights and obligations. For example, there could well be a legal right to provide a substitute worker and the fact that that right was never exercised in practice does not mean that it was not a genuine right.” 108. I need to refer to the decision of the Supreme Court in Bates van Winkelhof v Clyde & Co LLP[2014] 1 WLR 2057 . The claimant was a member of a Limited Liability Partnership. She claimed be entitled to the protection afforded to whistle-blowers under theEmployment Rights Act 1996 . For that purpose she needed to establish that she was a ‘limb (b) worker’. 109. The Supreme Court has rather altered the emphasis to be placed on various criteria that have been used to determine whether someone was a limb (b) worker. 110. Baroness Hale at 25: “the law now draws a distinction between two different kinds of self-employed people. One kind are people who carry on a profession or a business undertaking on their own account and enter into contracts with clients or customers to provide work or services for them. The arbitrators in Hashwani v Jivraj (London Court of International Arbitration intervening)[2011] 1 WLR 1872 were people of that kind. The other kind are self-employed people who provide their services as part of a profession or business undertaking carried on by someone else.” 111. She continued at 30: “it is necessary to consider the “more subtle” analysis addressed in the Court of Appeal, at para 71, that “underlying the statutory definition of ‘worker’ is the notion that one party has to be in a subordinate relationship to the other. At para 31 employment law distinguishes between three types of people: those employed under a contract of employment; those self-employed people who are in business on their own account and undertake work for their clients or customers; and an intermediate class of workers who are self-employed but do not fall within the second class.” 112. She then pointed to the absence of language in discrimination law of an express exception for those in business on their account who work for their clients or customers as is to be found ins230 of the Employment Rights Act but in the passage I cited earlier noted that the a similar qualification had been introduced by the decision of the European Court in Allonby . 113. She noted that the concept of subordination had been introduced by the ECJ in order to distinguish the intermediate class from people who were dealing with clients or customers on their own account and that concept was applied for the same purpose in the discrimination case of Hashwani v Jivraj to which I have referred. 114. Baroness Hale then considered a number of cases in the Employment Appeal Tribunal to which I have referred in which the Judges ‘attempted to capture the essential distinction in a variety of ways.’ These cases included: Byrne Brothers in which Mr Recorder Underhill QC (as he then was) considered that the intent of S230 (3) (b) was to afford protection to employees and workers who needed protection because their subordinate and dependent position vis-à-vis their employers. Such workers were to be distinguished from contractors who had a sufficiently arm’s-length and independent position to be treated as being able to look after themselves in the relevant respects. Cotswold in which Langstaff J laid stress on whether the purported worker actively markets his services as an independent person to the world in general on the one hand, or whether he is recruited by the principal to work for that principal as an integral part of the principal’s operations. Redcats in which Elias J, as he then was, looked beyond the degree of dependence and integration and subordination in favour of identifying the dominant purpose of the contract or its essence; was it in essence to be located in the field of dependent work relationships, or was it in essence a contract between two independent business undertakings? The purpose was to distinguish between the concept of worker and the independent contractor who is on business in his own account, even if only in a small way. Baroness Hale then referred to the decision of the Court of Appeal in Hospital Medical Group Ltd v Westwood[2013] ICR 415 , a case decided before the decision in the instant case and handed down on24 July 2012 ; the decision of the Court of Appeal in Bates van Winkelhof handed down on26 September 2012 ; Mr Nawbatt says that neither Counsel considered it to be relevant as it was decided on its own fact; and accordingly neither case was cited to the Employment Judge. The judgment in the instant case was sent to the parties on17 April 2012 . In Hospital Medical Group Ltd v Westwood the claimant was engaged in practice as a GP for the NHS but also provided services to a private clinic for which he carried out transgender work and also for the Respondent for whom he performed hair restoration surgery. The Court of Appeal held that insofar as his relationship with the Respondent was concerned he was a limb (b) worker. 115. I quote from Baroness Hale at 38: “Maurice Kay LJ pointed out, at para 18, that neither the Cotswold “integration” test nor the Redcats “dominant purpose” test purported to lay down a test of general application. In his view they were wise “to eschew a more prescriptive approach which would gloss the words of the statute”
“I do not consider that there is a single key with which to unlock the words of the statute in every case. On the other hand, I agree with Langstaff J that his ‘integration’ test will often be appropriate as it is here”. 39 I agree with Maurice Kay LJ that there is not “a single key to unlock the words of the statute in every case”
“In conclusion, we consider that where a party has an unfettered right for any reason not to personally perform the contractual obligations under a contract but can delegate them to someone else, he cannot be a ‘ worker ’ within the meaning of the WTR even though the person actually performing the contractual obligations has to meet certain conditions. The position would be different if the right not to perform the contractual obligation depended on some other event such as where that party was ‘ unable ’ to perform his or her obligations [or I would add unable to perform by reason of eg illness] I note that Premier Groundworks concerned a “worker” – not an employee. This decision was followed by HHJ McMullen in UK Mail Ltd v Creasey (November2012 UKEAT 0195/12 ) and by the EAT in Yorkshire Window Company v Parkes UKEAT 0484/09. In my opinion the principle should not be stated too widely and would not include a case in which prior permission was required to substitute. It must follow that if permission to substitute may be refused the right to substitute was either qualified or did not exist. 118. I have already referred to the principle that one of the necessary conditions for there to be a contract of employment is that the employee will provide his own work and skill in the performance of some service for his employer and that freedom to do a job either by one's own hands or by another's is inconsistent with a contract of employment ‘though a limited or occasional power of delegation may not be’; as put by Mackenna J in his judgement, in Ready Mixed Concrete . It seems to that ‘the limited power or occasional power of delegation,’ may now be interpreted more generously than heretofore and there are nice distinctions to be made between a restriction as to when or in what circumstances a substitution or delegation is permitted and a general permission to delegate; in the former case the limited restriction does not necessarily negate the obligation to provide services personally but in the latter case it does and thus the contract will not be a contract of employment. A restriction as to the persons to whom the work may be delegated does not necessarily negate the obligation to provide services personally, the absence of a restriction as to whom work may be delegated does negate the obligation. 119. An example of a case in which there was a limited power to delegate to persons on an approved register is MacFarlane and Another v Glasgow City Council[2001] IRLR 7 . In that case the Employment Appeal Tribunal held that gymnastic instructors, who worked at sports centres operated by Glasgow City Council under conditions that if they were unable to take a class, they would arrange for a replacement from a register of coaches maintained by the council might nonetheless be regarded as employees. They continued to have an obligation to personally perform their work. The Employment Appeal Tribunal remitted the case for further consideration to the Employment Tribunal. 120. I apprehend that in this regard the position of putative employees and limb (b) workers is similar; Premier Groundworks was a case involving limb (b) workers rather than employees. Even if the Respondent could establish that the Claimant had a contractual right to delegate his work or to provide a substitute the Claimant would still be considered to be a limb (worker) because his right was not unfettered. 121. Before leaving a consideration of the law, I need to remind myself of the importance of establishing mutuality of obligation, in particular in a case such as this where, if the Claimant is to succeed in his claims that it arose in periods when he was not carrying out assignments, it is necessary to establish that there was an overarching contract both in relation to the question of his employment and as to whether he was a “worker”
“...either perform the duties personally or engage another Pimlico contractor to do it for me at my own expense. I will remain responsible and liable for the acts and omissions of such person...”