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Case law
Autoclenz Ltd v Belcher

How you actually work can override what your contract says on paper.

The ruling

“Supreme Court held valeters were workers in law despite contracts labelling them self-employed.”

If the way you actually work doesn't match your contract, a tribunal can look past the paperwork and decide your rights based on what really happens.

  • Check whether any substitution clause in your contract has ever actually been used. An unused substitution clause carries little weight with a tribunal.
  • Keep a record of when you're told to work, what happens if you try to turn work down, and any pressure to be constantly available.
  • Get advice quickly if you think you've been mislabelled as self-employed. Claims tied to worker status usually have to reach a tribunal within three months less one day of the problem arising.
Read the full case

The situation

Car valeters were engaged by a company on contracts that described them as self-employed contractors. The contracts allowed workers to send someone else to do the job. There was no obligation on the company to offer work. Workers could refuse it too. In practice, the valeters had to turn up whenever they were told to, nobody had ever sent a substitute, and turning down work was not a real option.

What the court found

The Supreme Court looked past the paperwork. What counts is the true agreement between the parties, not the words used to describe it. Tribunals can look past the written document to how the work actually happened, and disregard any clause put there only to avoid giving workers their rights. Because no valeter had ever used the substitution clause, and none could realistically turn work down, the true relationship was one of employment, not self-employment.

The valeters were workers, entitled to rights under the Working Time Regulations and the National Minimum Wage Act.

Full citation

Autoclenz Ltd v Belcher. [2011] UKSC 41. Supreme Court. 27 July 2011.

Last reviewed 4 July 2026