The right to statutory leave is not inalienable but the employer must be fair and not act arbitrarily or otherwise unreasonably

Lyon v Mitie Security Ltd EAT [2010] UKEAT/0081/09/CEA

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20/01/2010

  • An employer must not be unreasonable, arbitrary or capricious in denying lawful requests for holiday.
When the claimant had no further work scheduled on the 6th March he asked his employer to payment for remaining holiday before the end of the current leave year on the 31 March. When he wasn't paid he left work citing the refusal to pay holiday pay and another reason.

An unfair dismissal claim ( constructive )for breach of trust and confidence followed. The failure to pay nine days holiday was the last straw.

According to the Working Time Regulations (WTR) Regulation 13 provides the, "Entitlement of four weeks" and Regulation 15 requires notice to the employer of twice as many days in advance of the number of days to which the notice relates.

The claimant argued that pursuant to the entitlement in Regulation 13, the statutory or contractual notice requirements are superseded by an inalienable right of an employee to take paid leave within the leave year.

The claimant was arguing that under WTR 13 the employer must permit an employee to take all paid leave within the leave year even if the employee makes his request towards the end of the leave year when it may not fit in with the staffing arrangements.

The EAT rejected this argument, ruling that the right to statutory leave is not inalienable but is subject to fairness. The employer must not be unreasonable, arbitrary or capricious in denying lawful requests.

The case of Stringer & Ors v Revenue & Customs Commissioners [2009] ICR 932 was referred to. Stringer determined that the right to paid annual leave continued at the end of a leave year where the worker had not had the opportunity to exercise that right because he was on sick leave.

Ansell J however interpreted Stringer as accepting the loss of a holiday right at the end of the leave year regarding leave not taken (p34).

The case was remitted to a different Tribunal for a rehearing.
The transcript of this case follows:-    Lyon v Mitie Security Ltd EAT [2010] UKEAT/0081/09/CEA


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