Agency Workers

In RSA Consulting Ltd v Dr Evans [2010] EWCA Civ 866, there was a quadripartite relationship where:

• Parasol Ltd employed Dr Evans to provide services for an end-user either directly or via a client such as RSA Consulting Ltd (RSA).
• Parasol Ltd had a contract with RSA to supply Dr Evans to an end-user (i.e. Pharmanet).
• RSA had a contract with Pharmanet.

Dr Evans made a claim for an unauthorised deduction from her wages against RSA even though there was no written contract between Dr Evans and RSA. The Court of Appeal held that it was arguable that there was an implied contract between the parties and the case was remitted to the employment tribunal.