Scullard v Knowles & Southern Regional Council for Education & Training

Scullard v Knowles & Southern Regional Council for Education & Training [1996] IRLR 344 is a UK labour law case, concerning equal pay.

Facts
Ms Scullard was a manager at a training unit of a charity. It had several units across the country. She wanted to compare herself to someone also employed by a Regional Advisory Council. Such Councils were funded by the Department for Employment, but were independent from the Secretary of State for Employment. The employer argued she could not compare men who worked in other units.

Judgment
Mummery J, as President of the EAT held that ‘associated employer’ under s 1(6) had no application because the different units were not limited companies within s 1(6). Instead, one had to rely on the wider provision of art 157, which has direct effect and ‘is not confined to employment in undertakings which have a particular legal form such as a limited company’