"Chris helped me draft the perfected grounds for appeal and the skeleton argument. All were submitted."
— Regine from Wembley
A claim form has arrived. The 28-day clock is running. A poorly-drafted ET3 narrows the defences you can run at final hearing and hands the claimant’s representative leverage from day one.
2026 reality: Most employment tribunal hearings are now remote (CVP video or telephone). Preliminary hearings almost always remote. Final hearings increasingly remote for straightforward cases.
Your job: review Chris’s drafts and sign. Chris is your personal PA — £500,000 worth of drafting capacity for the price of a Chinese takeaway, or from £30/month on Litigator Continued.
This guide is for employers — from single-director companies up to SMEs who want to defend proportionately. Chris drafts ET3 responses without the £3,000 employment solicitor fee. You sign, you file, you defend.
The 28-day deadline
From the date ET1 is received (not posted). Miss it and the Tribunal can enter default judgment. Apply for extension under Rule 20 with reasons and supporting evidence if needed.
Structure of ET3
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Chris can draft statements of case, witness statements, and application notices — written to the standard the court expects.
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- Employer identity and registered details
- Preliminary matters — jurisdictional challenges (time limits, service, employment status)
- Response to each factual allegation — admit, deny, no knowledge
- Positive defence case
- Relief sought — dismissal of claim, costs if appropriate
Preliminary matters — the strike-out levers
- Claim out of time
- Claimant not an employee or worker
- Claim has no reasonable prospect of success
- Scandalous or vexatious
Raise all applicable preliminary issues on ET3 so the Tribunal lists a preliminary hearing.
Let Chris draft this for you
Tell Chris what happened. Upload your contract, payslips, dismissal letter, correspondence. Chris drafts to the Litigant Standard™ — cold merit, exhibits numbered, tone pitched to the Employment Judge. You review. You sign. You submit.
Responding to each allegation
Paragraph-by-paragraph. “Paragraph 1 — admitted. Paragraph 2 — admitted as to dates; denied as to contractual terms; correct terms are [X] as set out in the attached contract of employment. Paragraph 3 — denied. The Respondent did not [act complained of]. The meeting on [date] was [actual content].”
Positive defence case
Not just denial. A coherent narrative. “The reason for dismissal was conduct / capability / redundancy / SOSR. The procedure followed was [steps]. The reasoning was [sound reason]. The decision fell within the band of reasonable responses of a reasonable employer.”
Polkey and contributory conduct
Even where liability is uncertain, plead Polkey (compensation reduction for procedural failure where substantive decision was still justified) and contributory conduct (reduction for claimant’s blameworthy conduct). These can reduce awards by 25–100%.
Can Chris draft ET3?
Yes. Upload the ET1, the contract, disciplinary papers, dismissal letter, investigation notes. Chris drafts ET3 paragraph-by-paragraph, with preliminary matters, positive defence, Polkey/contributory pleas, and the relief sought. £30 for a simple defence; Pro £88 for full-case defence through to hearing. £500k of PA work for the price of a Chinese takeaway applies to defendants too.
Prepare to win. Plan not to fail.
Employers who defend cleanly win cleanly. Chris drafts cleanly.
Did this help your case?
£500,000 of PA work for the price of a Chinese takeaway. Chris drafts — you sign. We would rather refund than file a document that isn’t ready.
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