A farm labourer has won almost €23,000 after the Workplace Relations Commission (WRC, Ireland's employment tribunal) found he worked an average of 77 hours a week over 19 weeks at a Co. Westmeath dairy.

Edward Lattich took the case against Mount Temple Dairy Farm Limited near Moate. He joined the farm in December 2024 to gain experience in the dairy sector. His monthly pay, he told the WRC, was a flat €2,500 regardless of hours worked.

What did the hours actually look like?

Lattich's submissions, backed where possible by photographs taken during his duties, logged monthly totals that the adjudicator found credible:

• Over 192 hours in December 2024;
• Over 353 hours in January 2025;
• Over 357 hours in February 2025;
• Over 366 hours in March 2025;
• Over 199 hours in April 2025.

He said he routinely worked about 14 hours a day, did not normally receive breaks, and spent most of his time on the farm's premises completing assigned tasks. From January 2025, hours increased in preparation for and during calving, and he generally worked every day of the week.

Why did the employer lose?

Adjudicator Brian Dolan described the complainant's documents as "impressive in their detail and precision" and determined that Lattich was underpaid by €10,420.13 in wages alone under the Payment of Wages Act. Further awards covered unpaid Sunday premium, unpaid public holiday entitlement, a missing daily rest period, a missing weekly rest period under the Organisation of Working Time Act, and outstanding annual leave on termination.

The decisive issue was record-keeping. The WRC was scathing about the farm's failure to keep any working time records. "In this particular case, no working time records of any description were maintained, and the burden of proof consequently fell upon the respondent to demonstrate accurate working hours," the findings stated.

What was the employer's defence?

Kelvin Hyland of Peninsula Business Services Ireland, acting for the respondent, disputed Lattich's calculations on both the extent of the underpayment and the finish times he submitted. The farm's accountant was instructed to recalculate the sums owed based on the national minimum wage and the employer's own record of hours worked. On that basis, Hyland said, the gross amount owed came to €6,895.07.

The WRC rejected that figure. It noted the respondent "essentially conceded liability" on the minimum wage complaint. The farm argued the arrangement was that longer hours during calving would even out over quieter periods of the farming calendar.

"Notwithstanding the foregoing, the respondent remained under a legal obligation to pay the complainant at least the national minimum wage for each hour worked in the course of his employment," the adjudicator said. "They accepted that they failed to do so, and having regard to the foregoing, the complaint is deemed to be well founded."

What does the ruling change for farm employers?

The mechanism here is simple. Without records, an employer cannot rebut a worker's evidence, however that evidence is gathered — and photographs taken on the job counted. The WRC's published statistics already point the same way: 42% of inspected agricultural workplaces breached employment law in a previous round of inspections.

Any dairy running spring calving on flat monthly pay should now check that total hours, divided across the pay period, still clear the national minimum wage. Farmers should watch for follow-on WRC decisions testing record-keeping duties, as adjudicators continue to apply the burden of proof against unrecorded hours.