판결 이유
In determining employment status, the court must look at the true agreement between the parties rather than the written terms of the contract where those terms do not reflect the reality. Sham or unrealistic contractual terms will be disregarded.
사실관계
Car valeters worked for Autoclenz under contracts stating they were self-employed independent contractors with a right to provide substitutes and no obligation to accept work. In reality, they worked regular hours, had no genuine right of substitution, and were treated as part of the workforce.
판결 요약
The Supreme Court held the valeters were workers (and potentially employees) despite the contractual documentation. The 'relative bargaining power' of the parties and the true nature of the arrangement must be considered. Written terms that do not reflect reality are to be disregarded.
주요 인용문
"The relative bargaining power of the parties must be taken into account in deciding whether the terms of any written agreement in truth represent what was agreed."
— Lord Clarke
후속 처리
Applied in Uber BV v Aslam [2021] UKSC 5, confirming that the Supreme Court will look beyond contractual labels to determine employment status.