“13(1) An employer shall not make a deduction from wages of a worker employed by him unless - (a) the deduction is required or authorised to be made by virtue of a statutory provision or a relevant provision of the worker’s contract, or (b) the worker has previously signified in writing his agreement or consent to the making of the deduction.” 15. At the original hearing before the ET the Respondent had denied making any deductions from the Claimants’ wages. By its reserved Judgment, however, the ET found that what the Claimants had said was true; deductions of£30 per week were made for accommodation. That was notwithstanding the Respondent having informed the Claimants that their accommodation would be free of charge. Given its position at the merits Hearing, it is right to say - and Mr Rees does not shy away from this - that no point had been raised as to the possibility of such deductions being authorised by virtue of a statutory provision. 16. The provision now relied on arises from theNational Minimum Wage Regulations 1999 , relevantly Regulation 30, which provides as follows: “The total of remuneration in a pay reference period shall be calculated by adding together - … (d) where the employer has provided the worker with living accommodation during the pay reference period, but in respect of that provision is neither entitled to make any deduction from the wages of the worker nor to receive any payment from him, the amount determined in accordance with regulation 36.” 17. Regulation 36 provides (paragraph (1)): “The amount referred to in [Regulation] 30(d) … is … (b) the amount resulting from multiplying the number of days in the pay reference period for which accommodation was provided by … ”
“… Failings of a party’s representatives, professional or otherwise, will not generally constitute a ground for review. That is a dangerous path to follow. It involves the risk of encouraging a disappointed applicant to seek to reargue his case by blaming his representative for the failure of his claim. That may involve the tribunal in inappropriate investigations into the competence of the representative who is not present at or represented at the review. …” (page 394) 22. The difficulty that arises in this case is that once the ET was engaged in having to recreate the wage history for the Claimants - as it had to do, to calculate the level of National Minimum Wage to which they are entitled - it was then operating under the statutory regime of the National Minimum Wage Act and the Regulations made thereunder. Given the ET’s finding of fact that£30 per week had been deducted for living accommodation, albeit there was no contractual right to do so, Regulation 30(6) meant that such a deduction was permitted because that sum could count towards the National Minimum Wage. The ET’s findings of fact in this regard were, however, made in a reserved Judgment. The question of how the calculation should be carried out on the basis of those specific findings had not been addressed. 23. Given the ET’s findings - which created a specific and new factual foundation that had implications for the calculation of National Minimum Wage - the Respondent was entitled to seek to take into account the benefit in kind of living accommodation. Moreover, in my judgment, given the way in which the point arose, it was in the interests of justice for the ET to allow this to be done on the reconsideration application. I agree with the Respondent: to refuse to consider the application in these circumstances constituted an error of law. 24. That is an error that can be corrected at this stage. Doing so, it is clear that there is only one possible result: the Respondent was entitled to make a deduction of£30 per week for living accommodation because this was allowed by statutory provision. It is thus a sum that should be permitted to count towards the Minimum Wage and not characterised as an unlawful deduction. 25. In terms of the awards made, the effect of that in Miss Hassan’s case will be to substitute a total of£5,459 (allowing deductions totalling£1,080 ) for that awarded by the ET, of£6,539.57 . In Mr Singh’s case the total award of£10,192.90 will, on this basis, now be subject to a reduction of£1,170 giving a substituted total, at this stage, of£9,022.90 . 26. I turn, then, to the second ground of appeal, which relates to the Respondent’s contention that Mr Singh’s compensatory award should have been calculated on net rather than gross pay. The Respondent relies on the well-known principle that it is not the purpose of the compensatory award in an unfair dismissal case to place a Claimant in a better position than s/he would have been in but for the dismissal. There can be no argument with that principle but the question for me is whether the ET erred in law in refusing to entertain the reconsideration application because the Respondent had not expressly made this point at the merits hearing. 27. It is not entirely clear how the Respondent’s case was put on this point below. The Respondent had not itself made deductions for tax and National Insurance from Mr Singh’s pay during his employment but that was because it had (wrongly) paid him at such a low level as to avoid such liabilities arising. Having reserved its Judgment, the ET had taken upon itself the calculation of Mr Singh’s unfair dismissal award, based on what it had found to be the correct level of pay. Only upon receiving the reserved Judgment and by its reconsideration application was the Respondent able to point out the error in the ET’s calculations. 28. The ET refused the application on the basis that it was entitled to calculate the award on a gross basis because that is how the Respondent had paid Mr Singh during his employment. That response, however, fails to engage with the fact that different circumstances applied when the ET was calculating its award. Given the ET’s calculation of the level of wages to which Mr Singh was properly entitled (applying National Minimum Wage), his pay would have been subject to tax and National Insurance and thus any compensatory award would need to be made net of those sums. Failing to do so, the ET was awarding Mr Singh more than the sum that would compensate him for losses he would actually have suffered. It was an error of approach that the Respondent could not have predicted. It was thus in the interests of justice to permit it to take the point by way of its application for reconsideration. Failing to do so was, in my judgment, an error of law on the ET’s part. 29. Adopting the correct approach must require Mr Singh’s award to be further reduced to take into account tax and National Insurance liabilities. Again it is appropriate for this exercise to be carried out at this stage and for the revised sum to be substituted for that awarded by the ET. Mr Rees has taken the trouble to demonstrate how that calculation should be made. Accepting his figures, which I am prepared to do, the further reduction is in the sum of£529.62 , which leads to a final total of£8,493.28 and that is the sum I substitute for the award made by the ET. I therefore allow the appeal and quash the original Judgment to the extent of those final totals and substitute my own awards in the sums that I have indicated. 30. Having given my Judgment in this matter, allowing the Respondent’s appeal, Mr Rees has made an application on behalf of his client for costs to the extent that those relate to the fees that the Respondent has had to pay in order to pursue this appeal. That application is made under Rule 34A(2A) of theEAT Rules 1993 as amended, which provides: “If the Appeal Tribunal allows an appeal, in full or in part, it may make a costs order against the respondent specifying the respondent pay to the appellant an amount no greater than any fee paid by the appellant under a notice issued by the Lord Chancellor.”