Case 2404411/2025 · Employment Tribunal
Mrs C A Ryan Palmer v General Medical Council Medical Practitioners Tribunal Service — 2026
- Case reference
- 2404411/2025
- Decision date
- 22 May 2026
- Jurisdiction
- England & Wales
- Judge
- Employment Judge Phil Allen
Parties
2 namedClaimant
Mrs C A Ryan Palmer
Key findings
Tribunal's reasoningMrs C A Ryan Palmer, formerly a lay fitness-to-practise panellist and lay chair, brought a claim for holiday pay following the decision in Somerville v NMC concerning the worker status of an NMC panel member. Her last day of work for the respondents was 22 July 2024 and her last payment was made on 4 August 2024. The Tribunal found that the primary deadline for presenting her claim, or commencing ACAS Early Conciliation, was 3 November 2024. Her first claim, presented on 1 May 2025 without prior ACAS Early Conciliation, was rejected. After Early Conciliation from 17 June to 29 July 2025, she presented the accepted claim on 12 August 2025.
The Tribunal applied the reasonably practicable test under section 23 of the Employment Rights Act 1996 and regulation 30 of the Working Time Regulations 1998. It accepted that the respondents' communications and the claimant's reliance on requests for patience were relevant, but did not find that the respondents had misrepresented the position or that anything prevented the claimant from presenting her claim in time. The Somerville decision had been determined before the primary limitation period expired, and the Tribunal found that it was reasonably practicable for the claimant to present her claim by 3 November 2024.
Because that finding disposed of the limitation issue, it was unnecessary to determine whether the claim had been presented within a reasonable further period. The Tribunal nevertheless stated that it would not have regarded presentation on 12 August 2025 as occurring within such a period, taking account of the delay and the failure to undertake Early Conciliation before the rejected claim. The Tribunal concluded that it lacked jurisdiction to consider the out-of-time unlawful deduction and holiday pay complaints, dismissed the claim, and made no monetary award.
Claims and outcomes
2 findings recorded| Claim type | Issue or finding | Outcome | Protected characteristic | Award |
|---|---|---|---|---|
| Unlawful deduction from wages | The complaint pursued as a deduction from wages under section 23 of the Employment Rights Act 1996 was dismissed because it was presented outside the applicable time limit and the Tribunal found that timely presentation had been reasonably practicable. | Dismissed | — | — |
| Holiday pay | The holiday pay complaint under regulation 30 of the Working Time Regulations 1998 was dismissed because it was presented outside the applicable time limit and the Tribunal found that timely presentation had been reasonably practicable. | Dismissed | — | — |
Legal tests applied
4 references- section 23 Employment Rights Act 1996 reasonably practicable test
- regulation 30 Working Time Regulations 1998 time-limit test
- Dedman v British Building and Engineering Appliances Ltd
- reasonable further period test
Official outcome judgment PDF
Gov.uk primary recordThe 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.
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.
Named in this case and want it removed? Submit a takedown request. The page will be withdrawn on receipt and the editor will follow up within five working days.