Ms S Barrett v Tamr Inc and 1 other — 2025

The claimant, Ms S Barrett, was employed by Tamr Ltd, the second respondent. Tamr Inc applied to strike out the claims against it on the basis that the claimant had presented no basis for claiming against the first respondent. The claimant's further particulars reaffirmed that her employment contract was at all material times with Tamr Ltd, and she did not plead that her employment had transferred to Tamr Inc.

The tribunal held that the unfair dismissal claim against Tamr Inc had no reasonable prospect of success because the claimant was employed by Tamr Ltd and had not shown any recognised basis for treating Tamr Inc as her employer. That claim was therefore struck out.

In relation to victimisation and sex discrimination, the claimant pleaded that US-based employees of Tamr Inc were acting as agents for Tamr Ltd and that their wrongful acts or omissions could be attributed to Tamr Ltd as principal. The tribunal held that, even if that pleaded passage might potentially raise liability issues for the individual employees, it did not provide a basis for liability against Tamr Inc because the claimant alleged the employees were acting for Tamr Ltd, not Tamr Inc. The tribunal therefore concluded that the victimisation and sex discrimination claims against Tamr Inc had no reasonable prospect of success and struck them out.