Dr Tim Noblet v St George’s University Hospitals NHS Foundation Trust — 2026

Dr Tim Noblet claimed unauthorised deductions from wages against St George's University Hospitals NHS Foundation Trust under section 13 of the Employment Rights Act 1996. He sought £38,591 for the difference between his Band 8b salary and Band 8d pay, which he said was due from October 2023. The tribunal dismissed the claim because the job evaluation had not produced a valid contractual entitlement to the higher salary.

The tribunal accepted that the evaluation was not an exercise undertaken by Noblet alone. Several managers reviewed the revised job description, HR became involved, paperwork passed through the Trust's internal processes and a Band 8d matching outcome was obtained. That outcome was communicated to Noblet on 4 April 2024. Managers then spent months discussing funding and implementation. The tribunal accepted that there was force in his argument that the Trust had treated this as a genuine job evaluation process.

The decisive issue was whether the matching outcome itself changed Noblet's contractual pay entitlement or whether valid managerial approval was required first. The Agenda for Change provisions and Job Evaluation Handbook formed part of his contract, but the handbook did not create an automatic right to higher pay whenever a job description changed. The tribunal relied on its provision for locally agreed procedures and considered the business efficacy and officious bystander tests for implied terms. It found that the Job Evaluation Verification Form supplied the necessary requirements for managerial approval and funding safeguards.

The form required approval from the appropriate line manager, budget holder and Divisional Director of Operations. Noblet was employed within CWDT, but his line manager, Ms Baillie, and the relevant senior approver, Ms Benson, had not given the necessary approval. Mr Fitzpatrick signed from SNCT despite not being Noblet's line manager. Contemporaneous emails showed that paperwork had been submitted while approval was still being sought. Noblet could not point to documents showing that funding for a Band 8d role had been formally approved.

The tribunal did not treat the dispute over whether Noblet had been required to perform additional duties as decisive; the question was whether a contractual right to Band 8d pay had arisen. It also discounted Annex 31 because it was dated February 2026 and there was no indication that its provisions existed at the relevant time. Because the required approvals were absent, there was no valid contractual variation and Band 8d wages were not properly payable. The complaint was not well-founded and no monetary remedy was awarded.