Groom v Maritime & Coastguard Agency (2024)

Mr. Groom served as a volunteer Coastal Rescue Officer for the Coastguard Rescue Service (CRS). Despite being labelled a volunteer, he was entitled to claim remuneration for specific activities, such as attending incidents and training sessions. When denied the right to be accompanied by a trade union representative at a disciplinary hearing—a right reserved for workers—he challenged his status.)

The Employment Appeal Tribunal (EAT) determined that:

A contract existed during activities for which Mr. Groom was entitled to remuneration, regardless of whether he submitted a claim. The presence of mutual obligations and the personal performance of services indicated worker status. This case underscores that the reality of the working relationship, not just the label of "volunteer," determines employment status.

Murray v Newham Citizens Advice Bureau (2000)

Mr. Murray volunteered under an agreement specifying set times and a minimum commitment period. The bureau reimbursed his expenses and provided basic training. The Employment Appeal Tribunal found that these arrangements constituted a contract of employment, thereby classifying him as an employee.

Maria DeLourdes Armitage v Relate (1994)

Mrs. Armitage served as a volunteer counsellor with Relate. Her agreement required her to provide a minimum number of counselling hours weekly and stipulated that if she left before completing 600 hours, she would need to repay some training costs. Additionally, there was an expectation of future paid work. The tribunal determined that these mutual obligations and the anticipation of paid employment established a contract of employment, allowing her to proceed with a racial discrimination claim.

Migrant Advisory Service v Chaudri (1975)

Mrs. Chaudri performed administrative work for the Migrant Advisory Service for two years, receiving a fixed weekly sum labelled as "expenses," despite incurring none. The Employment Appeal Tribunal concluded that this regular payment, coupled with her consistent work schedule, established an employment relationship, granting her employee rights.