Employment contract in English law
An employment contract in English law is a specific kind of contract whereby one person performs work under the direction of another. The two main features of a contract is that work is exchanged for a wage, and that one party stands in a relationship of relative dependence, or inequality of bargaining power. On this basis, statute, and to some extent the common law, requires that compulsory rights are enforceable against the employer.
There are diverging views about the scope by which English law covers employees, as different tests are used for different kinds of employment rights, legislation draws an apparent distinction between a "worker" and an "employee", and the use of these terms are also different from their use in the European Court of Justice and European Union Directives. Under the Employment Rights Act 1996 section 230, an "employee" is anyone with a contract of service, which takes its meaning from a series of court cases that are also applicable for tax and tort law, where different judges have given different views about the meaning of the word. An "employee" is entitled to all types of rights that a worker has, but in addition the rights to reasonable notice before a fair dismissal and redundancy, protection in the event of an employer's insolvency or sale of the business, a statement of the employment contract, rights to take maternity leave or time off for child care, and an occupational pension.
A "worker" is a broader concept in its statutory formulation, and catches more people, but does not carry as many rights. A worker means any person who personally performs work, and is not a client or a customer. A worker is entitled to a minimum wage, holidays, to join a trade union, all anti-discrimination laws, and health and safety protection.
Scope of employment rights
As yet, the UK has not consolidated a comprehensive definition of the people to whom employment rights and duties apply. Statute and case law, both domestic and European, use 2 main definitions, with approximately six others. The EU does have one consolidated definition of a ‘worker’, which is someone who has a contract for work in return for a wage, and also stands as the more vulnerable party to the contract. This reflects the kernel of classical labour law theory, that an employment contract is one infused with “inequality of bargaining power”, and stands as a justification for mandating additional terms to what might otherwise be agreed under a system of total freedom of contract.UK courts have agreed that an employment contract is one of a specific type, and that it cannot be equated with a commercial agreement. However, UK statutes deploy two main definitions, of an ‘employee’ and a ‘worker’, with a different number of rights. The government may also pass secondary legislation to include specific groups of people into the ‘employee’ category. An ‘employee’ has all available rights. The meaning is explicitly left to the common law under the main statute, the Employment Rights Act 1996 section 230, and has developed according to the classical 19th century contrast between a contract ‘of service’ and one ‘for services’. While the classical test was that an employee was subject to a sufficient degree of ‘control’, new forms of work where people were had greater autonomy outside the factory to choose how to do their jobs, meant that, particularly from the mid-20th century, additional tests of employment were developed. Multiple factors, including how much one could be said to be ‘integrated’ into the business, or whether one metaphorically wore the ‘badge’ of the organisation, were looked at, with a focus, it was said on ‘economic reality’ and form over substance. Multiple relevant factors would include how much the employee was ‘controlled’, if they owned their tools, if they had the chance of profit and bore the risk of loss. But in the late 1970s and 1980s, some courts began to speak of a new test of ‘mutuality of obligation’. One view of this was merely that workers exchanged work for a wage. Another view stated that the employment relationship had to be one where there was an ongoing obligation to offer and accept work. This led to cases where employers, typically of people on low wages and little legal understanding, pleaded that they had only hired a person on a casual basis and thus should not be entitled to the major job security rights.
In addition, a ‘worker’ is defined in ERA 1996 section 230 as someone with a contract of employment or who personally performs work and is not a client or a customer. So this concept has greater scope, and protects more people, than does the term ‘employee’. This class of person is entitled to a safe system of work, a minimum wage and limits on working time, as well as discrimination and trade union rights, but not job security, child care and retirement rights. This concept thus reaches up to protect people who are quasi-self-employed professionals, albeit not so vulnerable, such as a home cleaner, or music teacher who visits student homes, or in certain cases a taxi cab driver.
- Autoclenz Ltd v Belcher
- Jivraj v Hashwani UKSC 40, arbitrators do not have employment contracts.
- Governing Body of Clifton Middle School v Askew ICR 286, employment relationship
- Edmonds v Lawson EWCA Civ 69, IRLR 391, pupillage, not an apprentice?
- Mingeley v Pennock and Ivory EWCA Civ 328, taxi driver wearing the organisation’s badge
- Hall v Woolston Hall Leisure Ltd , illegality does not lose someone discrimination protection
- Beloff v Pressdram Ltd 1 All ER 241
- Ferguson v John Dawson & Partners Ltd , 1 WLR 1213, Megaw LJ, declarations of employee status to be "wholly disregarded"
- Calder v H Kitson Vickers & Sons Ltd ICR 232, 251, Ralph Gibson LJ says declarations are not conclusive, but relevant
- Newnham Farms Ltd v Powell EAT/0711/01/MAA, employment contract arising from conduct
- Aslam v Uber BV, scope of employment rights for Uber drivers, "worker" concept
- Clark v Oxfordshire HA IRLR 125
- Hall v Woolston Hall Leisure Ltd IRLR 578, dependent entrepreneur
- Consistent Group v Kalwak EWCA Civ 430
- Lemmerman v. A.T. Williams Oil Co., 350 S.E.2d 83
Employment rights
- statement of contract, ERA 1996 s 1
- reasonable notice, ERA 1996 s 86
- unfair dismissal, ERA 1996 s 94
- redundancy, ERA 1996 s 139
- guaranteed pay on employer insolvency, ERA 1996 s 94
- TUPER 2006, Business Transfers Directive 2001/23
- maternity, paternity and parental leave
- request flexible working time, ERA 1996 s 80F
- right to return to work
- Information and Consultation of Employees Directive 91/533
- Income Tax Act 2003, Part 11, employed earner, ‘gainfully employed under a contract of service’
- contributions to National Insurance, SSCBA 1992 ss 1 and 2
- union organisation, TULRCA 1992
- minimum wage, NMWA 1998
- 28 days holiday, working time limits, WTR 1998
- Collective Redundancies Directive 98/59, though UK reg’s used ‘employee’
- free movement within EU, TFEU, C 53/91 Levin and C 256/01 Allonby
Construction of employment
- France v James Coombes & Co AC 496
- Lloyds Bank Ltd v Bundy QB 326
- Pao On v Lau Yiu Long UKPC 2
- National Westminster Bank plc v Morgan 1 All ER 821
- Johnson v Unisys Limited UKHL 13
- Reda v Flag Ltd UKPC 38
- Gisda Cyf v Barratt UKSC 41
- Autoclenz Ltd v Belcher UKSC 41
Express terms
- Statutory compulsory terms: right to statement, payment of wages, notice, fair dismissal, redundancy, minimum wage, working hours, pension
- British Telecommunications plc v Ticehurst ICR 383
- Cheltenham Borough Council v Laird EWHC 1253 QB, on misrepresentations before entering an employment contract
Incorporation of terms
- Parkwood v Alemo – Herron IRLR 298, incorporation of varying collective agreement terms
- Trade Union and Labour Relations Act 1992, ss 179, 180, 236
- Harlow v Artemis International Corp Ltd , online redundancy incorporated
- Johnstone v Bloomsbury Health Authority 2 All ER 293, law implied, safe work over flex cl
- Henry v London Greater Transport Services Ltd , varying collag binding maybe w/o vote
- Robertson v British Gas Corp ICR 351, bonus in collag binding
- Alexander v Standard Telephones & Cables Ltd IRLR 287 13
- Camden Exhibition & Display Ltd v Lynott 1 QB 555 13
- Malone v British Airways plc IRLR 431; EWHC 302 incorporation of perks into from a collective agreement into individual contract and variation
Implied terms favouring employees
The second, and older hallmark of the employment contract is that employees are bound to follow their employers’ instructions while at work, so long as that does not contravene statute or their agreed terms. Every employment relation leaves the employer with a residue of discretion, historically expressed as the ‘master-servant’ relationship. Today, in practice, this leaves the employer with the ability to vary the terms of work in accordance with business need. The courts have allowed this to continue, so long as it does not contradict a contract’s express terms, which always require an employee’s consent, or renegotiation of a collective agreement. However, it has also been held that employers may insert ‘flexibility clauses’ allowing them to reserve the right to vary any contract term. The limits of the courts’ tolerance of such practices are evident if they touch procedures for accessing justice, or potentially if they would contravene the duty of mutual trust and confidence.
- Master and servant: discretion of employer outside written terms, flexibility
- Devonald v Rosser & Sons 2 KB 728, fact implied, risk of no work
- Sagar v Ridehalgh & Sons Ltd 1 Ch 310, implied by custom, wage deductions
- Wilsons and Clyde Coal Ltd v English AC 57, law implied, safe work
- Wilson v Racher ICR 428, mtc manners, justifying termination
- Mahmud and Malik v BCCI SA AC 20, mtc implied, law implied, reputation
- Transco plc v O'Brien EWCA Civ 379, mtc implied for equal treatment
- Crossley v Faithful & Gould Holdings Ltd EWCA Civ 293, law, not implied for finance advice
- Woods v WM Car Services Ltd ICR 666, EAT; ICR 693 11
- Baldwin v Brighton and Hove City Council IRLR 232, ICR 680 11
- Crowson Fabrics Ltd v Rider IRLR 288; EWHC 2942 11
- Home Office v Evans EWCA Civ 1089, IRLR 59 12
- The Post Office v Roberts IRLR 347 12
- Mallone v BPB Industries plc EWCA Civ 126 12
- Luke v Stoke County Council EWCA Civ 761 13
Implied terms favouring employers
- Cresswell v Board of Inland Revenue ICR 508, using new technology, er discretion
- Dryden v Greater Glasgow Health Board IRLR 469, varying work rule book no breach
- French v Barclays Bank plc IRLR 646, bridge loan withdrawal mtc breach
- Alexander v Standard Telephones & Cables Ltd IRLR 287, collag with lifo not intended incorp
- Kaur v MG Rover Group Ltd EWCA 1507, collag, no comp redundancy not intended
- Rigby v Ferodo Ltd ICR 29, wage reduction, insist on terms
- Hussman Manufacturing Ltd v Weir IRLR 288 13
- Jones v Associated Tunnelling Co Ltd IRLR 477 14
- Wandsworth London Borough Council v D’Silva IRLR 193 14
- United Bank Ltd v Akhtar IRLR 507 14
- Lee v GEC Plessy Telecommunications Ltd IRLR 383 14
- Bateman v ASDA IRLR 370, complete flexibility clause
- Harlow v Artemis International Corp Ltd IRLR 629; EWHC 1126 variation and termination of the employment contract
Performance, breach and termination
- Wiluszynski v London Borough of Tower Hamlets ICR 439, strike wages, part performance
- Secretary of State for Employment v ASLEF ICR 19, work to rule, no good faith is breach
- British Telecommunications plc v Ticehurst ICR 383, work to rule, part performance
- Johnson v Unisys Limited UKHL 13
- Buckland v Bournemouth University IRLR 445
Theory of employment
- FW Taylor, Scientific Management
- FJ Roethlisberger and WJ Dickson, Management and the Worker
- D Guest and R Peccei, ‘Partnership at Work: Mutuality and the Balance of Advantage’ 39 BJIR 207, employers emphasise the mutual gains that can be achieved by partnership between management and workers.
- D Katz, ‘The Motivational Basis of Organisational Behavior’ 9 Behavioural Science 131
- CA Smith, DW Organ and JP Near, ‘Organisational Citizenship Behavior: Its Nature and Antecedents’ 68
- P Rosenthal, S Hill and R Peccei, ‘Checking Out Service: Evaluating Excellence, HRM and TQM in Retailing’ 11 Work, Employment and Society 481
- D Ariely, The Upside of Irrationality chs 1-3