Mr R Messenger v Focus 24 Limited — 2021

Case reference: 2206500/2020
Decision date: 14 January 2021
Jurisdiction: England & Wales
Judge: Employment Judge Smailes

Indexed: 23 May 2026

Parties

2 named

Claimant

Mr R Messenger

Respondent

Focus 24 Limited

Key findings

Tribunal's reasoning

Mr R Messenger brought a complaint of unlawful deduction from wages against Focus 24 Limited. The case was heard remotely at London Central on 14 January 2021 before Employment Judge Smailes sitting alone.

The tribunal held that the complaint had been issued outside the statutory time limit for claims of this kind under s23 Employment Rights Act 1996. It further found that it was reasonably practicable for the claim to have been issued in time.

On that basis, the tribunal concluded that it did not have jurisdiction to hear the complaint and dismissed the claim.

Claims and outcomes

1 finding recorded

Claim type	Issue or finding	Outcome	Protected characteristic	Award
Unlawful deduction from wages	The tribunal found the complaint was issued outside the statutory time limit under s23 Employment Rights Act 1996 and that it was reasonably practicable for it to have been issued in time, so it had no jurisdiction to hear the claim.	Dismissed	—	—

Legal tests applied

1 reference

Official outcome judgment PDF

Gov.uk primary record

The official judgment PDF on gov.uk contains the tribunal's outcome, reasoning, and any remedy details. Where this page does not yet show extracted outcomes for every claim, use the PDF as the authoritative source.

Open official judgment PDF on gov.uk

Published on gov.uk under the Open Government Licence v3.0.

How we got this data

Case essentials (reference, date, judge, venue, country, claim categories) are extracted from the structured metadata gov.uk publishes alongside each decision. Parties and monetary figures are extracted from the judgment PDF text. Key findings and per-claim outcomes require a second extraction pass that is not yet complete for this case — until then, the primary source linked above is the authoritative record. See full methodology.

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