Maritime and Coastguard Agency v Martin Groom

Maritime and Coastguard Agency v Martin Groom

A Coastguard Rescue Officer who attends an activity for which remuneration is payable is a 'worker' within the meaning of s 230(3)(b) of the Employment Rights Act 1996, as there is a contract for the provision of services, mutuality of obligation during the period of work, and an intention to create legal relations,...

Source-derived case information.

Parties
Appellant: Maritime and Coastguard Agency; Respondent/claimant: Martin Groom
Jurisdiction
England and Wales
Judgment Date
14 January 2026
Procedural Posture
Appeal / Judgment of the Court of Appeal on Appeal From the Employment Appeal Tribunal
Outcome
Appeal dismissed
Legal Topics
Worker Status, Remuneration, Mutuality of Obligation, Intention to Create Legal Relations, Statutory Interpretation, Volunteer Rights
Employment Law Worker Status Remuneration Mutuality of Obligation Intention to Create Legal Relations Statutory Interpretation Volunteer Rights

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Parties

Maritime and Coastguard Agency

Appellant

Martin Groom

Respondent/claimant

Procedural Posture

Appeal / Judgment of the Court of Appeal on Appeal From the Employment Appeal Tribunal

Legal Issues

  1. 1 Whether a Coastguard Rescue Officer (CRO) is a 'worker' within the meaning of s 230(3)(b) of the Employment Rights Act 1996 when attending activities for which remuneration is payable
  2. 2 Whether the relationship between the CRO and the MCA is contractual or purely voluntary
  3. 3 Whether mutuality of obligation and intention to create legal relations exist in the relationship

Ratio Decidendi

A Coastguard Rescue Officer who attends an activity for which remuneration is payable is a 'worker' within the meaning of s 230(3)(b) of the Employment Rights Act 1996, as there is a contract for the provision of services, mutuality of obligation during the period of work, and an intention to create legal relations, regardless of the absence of obligation outside those periods or the use of the term 'volunteer'.

Court Disposition

Appeal dismissed

Orders

  • The appeal by the Maritime and Coastguard Agency is dismissed.
  • The finding that Mr Groom was a 'worker' at the relevant time is upheld.