Whittlestone v BJP Home Support Ltd (National Minimum Wage) [2013] UKEAT 0128_13_1907 (19 July 2013)

Whittlestone v BJP Home Support Ltd (National Minimum Wage) [2013] UKEAT 0128_13_1907 (19 July 2013)

The Claimant's sleepover hours and travelling time between assignments were 'time work' under the National Minimum Wage Regulations, and the deduction for alleged overpayment was unlawful as the Tribunal overlooked Employment Rights Act s.89.

Citation
[2013] UKEAT 0128_13_1907
Parties
Claimant: Mrs Whittlestone; Respondent: BJP Home Support Ltd
Jurisdiction
United Kingdom
Judgment Date
19 July 2013
Procedural Posture
Employment Appeal / Appeal From Employment Tribunal
Outcome
Appeal allowed
Legal Topics
National Minimum Wage, Time Work, Travelling Time, Unlawful Deduction From Wages

Case Brief

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Parties

Mrs Whittlestone

Claimant

BJP Home Support Ltd

Respondent

Procedural Posture

Employment Appeal / Appeal From Employment Tribunal

  1. 1 Whether sleepover hours constitute 'time work' for National Minimum Wage purposes
  2. 2 Whether travelling time between assignments is 'time work'
  3. 3 Whether deduction for alleged overpayment was lawful

Ratio Decidendi

The Claimant's sleepover hours and travelling time between assignments were 'time work' under the National Minimum Wage Regulations, and the deduction for alleged overpayment was unlawful as the Tribunal overlooked Employment Rights Act s.89.

Court Disposition

Appeal allowed

Orders

  • Finding substituted that Claimant was entitled to have sleepover and travelling time included in National Minimum Wage calculation
  • Matter remitted for calculation of pay and further argument