Halliburton Management Ltd

Case Summary

The claimant claimed unlawful deduction of wages, alleging he performed Data Engineer work from July 2024 but was only paid at the Logging Geologist rate until 31 March 2025. The tribunal found it had no jurisdiction to hear the claim because the time limit under ERA 1996 s.23(2) commenced on 31 March 2025 (when the claimant received the last payment in the disputed series) and the claim was not presented until 11 October 2025, well outside the primary 3-month limit and any reasonable extension period.

The tribunal found that the time limit for presenting the unlawful deduction of wages claim commenced on 31 March 2025 when the claimant received the last payment in the disputed series, and the 3-month primary limit expired on 28 July 2025. The claimant did not present his claim until 11 October 2025, which was outside the primary time limit and any reasonable further period. The claimant was a sophisticated individual who ought to have understood the applicable time limit and proceeded on a mistaken belief about when the time limit commenced, not from ignorance of the right itself.

Use these claim-type pages to compare this decision with other published tribunal cases, outcome patterns, and visible award data.

• •Jurisdiction - time limit for unlawful deduction of wages claim under ERA 1996 s.23(2)
• •Whether the 3-month primary time limit commenced on 31 March 2025 (last payment in disputed series) or 29 May 2025 (first payment at higher rate)
• •Whether it was reasonably practicable to present claim within time limit
• •Application of ACAS Early Conciliation extension

EMPLOYMENT TRIBUNALS (SCOTLAND) Case No: 4103769/2025 Held in Glasgow via Cloud Video Platform (CVP) on 2 March 2026 Employment Judge R McPherson Mr Alexander Lazenby Claimant Represented by: Mr M Salt - Lay Representative Halliburton Management Ltd Respondent Represented by: Ms C Law - Solicitor JUDGMENT OF THE EMPLOYMENT TRIBUNAL The judgment of the Employment Tribunal is that the Tribunal does not have jurisdiction in relation to the claimant’s claim of unlawful deduction of wages, and the claims are dismissed. REASONS Introduction Preliminary procedure 1. On 11 October 2025, the claimant’s ET1 was presented, asserting complaints of unlawful deduction of wages. The claimant argues that, between July 2024 and March 2025, he was deployed and worked as a Data Engineer but was paid at a lower rate for a Logging Geologist until the end of March 2025, which he argues amounts to an unlawful deduction of wages. 2. The respondent resists the claims, including setting out that the Tribunal did not have jurisdiction to hear a claim for unpaid wages as the time limit had expired before the presentation of a claim and did not have jurisdiction to hear a claim for breach of contract, in that the claimant’s employment is ongoing, and further (at 3.3) that the respondent’s position is that they were not under legal obligation to pay claimant a higher rate for work performed prior to 1 April 2025, the respondent arguing that the higher rate entitlement arose from 4103769/2025Page2 1 April 2025 when the claimant was promoted to the position of Data Engineer. 3.At the outset of this hearing, Mr Martin Salt, who was the claimant’s uncle, explained that while he had a background in law several years previously, this was not in litigation or employment law. He was acting as a lay representative.…