Case 3314364/2023 · Employment Tribunal
Mr Richard Luckraft v Chief Constable of Bedfordshire Police Preliminary Hearing — 2024
- Case reference
- 3314364/2023
- Decision date
- 16 October 2024
- Jurisdiction
- England & Wales
- Judge
- Employment Judge Boyes
Parties
2 namedClaimant
Mr Richard Luckraft
Key findings
Tribunal's reasoningThis was a reserved judgment following a preliminary hearing before Employment Judge Boyes (sitting alone) at Watford on 31 May 2024 to determine whether the Tribunal had jurisdiction to hear the claimant's complaints. The claimant, a Fingerprint Team Leader within the Scientific Services Unit, brought a complaint of unauthorised deductions from wages in respect of approximately 402 hours of overtime he said had been worked but neither paid nor compensated by time off in lieu. Early conciliation took place between 17 October and 28 November 2023 and the ET1 was lodged on 11 December 2023.
The Tribunal found that the complaint had been presented outside the primary three-month time limit. It was satisfied that it had not been reasonably practicable for the claimant to lodge his claim by 27 July 2023, given his continuing employment and a not unrealistic expectation that the matter would be resolved internally up to the rejection of the Fairness at Work recommendations on 5 September 2023. However, the Tribunal found that the further period taken thereafter was not reasonable: from 13 October 2023 onwards the claimant was demonstrably mindful of potential time limits, his union and Acas were involved, and on 20 November 2023 Acas expressly advised him about the three-month limit and to take legal advice, yet he did not lodge his claim until 22 days later.
Accordingly the Tribunal held that it had no jurisdiction to determine the unauthorised deductions complaint. The claimant's whistleblowing complaints, which he confirmed he did not intend to pursue, were dismissed on withdrawal. No remedy was determined at this preliminary hearing.
Claims and outcomes
2 findings recorded| Claim type | Issue or finding | Outcome | Protected characteristic | Award |
|---|---|---|---|---|
| Unlawful deduction from wages | Preliminary hearing on jurisdiction. Tribunal found the complaint of unauthorised deductions from wages was presented outside the primary three-month time limit. Although it was not reasonably practicable to lodge in time, the further period taken was not reasonable. Tribunal therefore had no jurisdiction to determine the claim. | Dismissed | — | — |
| Whistleblowing | Claimant confirmed at the hearing that he did not intend to pursue the whistleblowing complaints referred to at paragraphs 11-13 of section 8.2 of the ET1 and wished to withdraw them. On withdrawal, the complaint was dismissed. | Withdrawn | — | — |
Remedy
Monetary award- Total award
- £0
- across all upheld claims
Legal tests applied
2 references- section 13 Employment Rights Act 1996
- reasonably practicable test (unauthorised deductions time limit)
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.
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