"'stable employment case' means a case where the proceedings relate to a period during which a stable employment subsists between the woman and the employer, notwithstanding that the period includes any time after the ending of a contract of employment when no further contract of employment is in force."
“3. In circumstances where: (a) an employee has served under a number of separate contracts of employment for the same employer covering defined periods of time and with intervals between the periods covered by the contracts of employment; (b) after completion of any contract, there is no obligation on either party to enter into further such contracts; and (c) she initiates a claim within six months of completion of a later contract or contracts but fails to initiate a claim within six months of any earlier contract or contracts: is a national procedural rule which has the effect of requiring a claim for membership of an occupational pension scheme from which the right to pension benefits flow to be brought within six months of the end of any contract or contracts of employment to which the claim relates and which, therefore, prevents service under any earlier contract or contracts from being treated as pensionable service compatible with: (i) the right to equal pay for equal work in Article 119 of the EC Treaty; and (ii) the principle of EC law that national procedural rules for breach of Community law must not make it excessively difficult or impossible in practice for the claimant to exercise her rights under Article 119?” 43. The CJEU observed at paragraph 65: “This question relates to a number of actions before the national court which are distinguished by the fact that the claimants work regularly, but periodically or intermittently, for the same employer, under successive legally separate contracts. According to the order for reference, in the absence of an umbrella contract, the period prescribed in s2(4) of the EPA starts to run at the end of each contract of employment and not at the end of the employment relationship between the worker and the establishment concerned. It follows that workers are unable to secure recognition of periods of part-time work for the purpose of calculating their pension rights unless they have instituted proceedings within six months after the end of each contract under which the work concerned was performed.”
“the date on which the sequence of such contracts has been interrupted through the absence of one or more of the features that characterise a stable employment relationship of that kind, either because the periodicity of such contracts has been broken or because the new contract does not relate to the same employment or that to which the same pension scheme applies. [70]”
“The answer to the third question must therefore be that Community law precludes a procedural rule which has the effect of requiring a claim for membership of an occupational pension scheme (from which the right to pension benefit flows) to be brought within six months of the end of each contract of employment to which the claim related where there has been a stable employment relationship resulting from a succession of short-term contracts concluded at regular intervals in respect of the same employment to which the same pension scheme applies.[72]” 44. The CJEU accordingly held that domestic law should enable claimants who work regularly but periodically or intermittently for the same employer under successive legally separate contracts to bring equal pay claims within a limitation period starting on the date on which the sequence of such contracts has been interrupted. The court explained that the features characterising a stable employment relationship are a succession of contracts concluded at regular intervals. The ‘periodicity’ of such contracts is a necessary feature of such relationships. In my judgment it is apparent that the CJEU considered that a stable employment relationship could continue beyond the end of a particular contract. It would however come to an end if no new contract were entered into by the time expected in accordance with the established pattern, or periodicity, of the parties entering into such contracts. 45. Some of the Claimants in Preston were employed under consecutive but separate contracts of service with breaks in between. The stable employment relationship continued over such breaks. When the case returned to the House of Lords after the CJEU had given their judgment on the reference, Lord Slynn held that the Respondents could not rely on the six month limitation period in EqPA Section 2(4) starting at the end of each contract of employment to which the claim relates “where there has been a stable employment relationship resulting from a succession of short-term contracts concluded at regular intervals…”
“He was guaranteed no work in the future, and there was no obligation on the Respondent to offer him work.” is the language of the mutual obligation test for the existence of a contract of employment or an ‘umbrella contract’. It is not the test for a stable employment relationship. 49. In considering the absence of a contract of employment or an overarching ‘umbrella’ contract relevant to the question of whether there was a stable employment relationship between the parties in the period from3 July 1995 and4 January 1996 , the EJ erred in law. 50. In paragraph 5.2 of his conclusions the EJ held that this was not case of a ‘temporary cessation of work’. Temporary cessation of work is not a term used in the EqPA . It has a particular statutory meaning for the purpose of claims under the ERA . It is not clear why the term was used in the context of this equal pay claim. The CJEU and the House of Lords in Preston made clear that ‘stable employment relationship’ was a new and different concept. This was emphasised in Fox . It was not suggested that ‘continuous employment’ under the ERA had any relevance to determining whether a ‘stable employment relationship’ existed for the purposes of an equal pay claim. 51. I do not accept the proposition advanced by Counsel for the Claimant that “in determining whether there was a stable employment relationship the EJ failed to have regard to the fact that a stable employment relationship cannot be narrower than continuous employment within the meaning S212 ERA.”
“Nor was this a temporary cessation of work, because the work continued for full-time lecturers, and possibly other part-time lecturers.”
“there was no work for the Claimant, save for a few ad hoc days, in the Autumn of 1995. When the Autumn term started again in September 1995, there was no work for the Claimant, so there was no continuity of employment through the summer holidays into that term.” and that: “On the definition of stable employment relationship given in Preston , that relationship came to an end and there was no relationship from July 1995.” 56. The test for ascertaining whether there was a stable employment relationship between July 1995 and January 1996 is whether there was a succession of contracts of employment concluded at regular intervals, with or without gaps between them ( Slack ) and irrespective of the length of the contracts. Carnwath LJ in Fox held at paragraph 28: “…if stability of the relationship is the guiding principle, it would be perverse to held that a succession of long-term contracts cannot achieve the same result.”
“33. Accordingly it is clear that where there are intermittent contracts of service without a stable employment relationship, the period of six months runs from the end of each contract of service, but where such contracts are concluded at regular intervals in respect of the same employment regularly in a stable employment relationship, the period runs from the end of the last contract forming part of that relationship.”
“They did the same work for the Council over very many years without any break in the work they did or in the succession of contracts.”