"What the parties privately intended or expected (either before or after the contract was agreed) may be evidence of what, objectively discerned, was actually agreed between the parties: see Lord Hoffmann's speech in the Chartbrook case at [64] to [65]. But ultimately what matters is only what was agreed, either as set out in the written terms or, if it is alleged those terms are not accurate, what is proved to be their actual agreement at the time the contract was concluded. I accept, of course, that the agreement may not be express; it may be implied. But the court or tribunal's task is still to ascertain what was agreed."
"recognising as it does that while employment is a matter of contract, the factual matrix in which the contract is cast is not ordinarily the same as that of an arm's length commercial contract."
“In order to decide whether a person carries on business on his own account it is necessary to consider many different aspects of that person's work activity. This is not a mechanical exercise of running through items on a check list to see whether they are present in, or absent from, a given situation. The object of the exercise is to paint a picture from the accumulation of detail. The overall effect can only be appreciated by standing back from the detailed picture which has been painted, by viewing it from a distance and by making an informed, considered, qualitative appreciation of the whole. It is a matter of evaluation of the overall effect of the detail, which is not necessarily the same as the sum total of the individual details. Not all details are of equal weight or importance in any given situation. The details may also vary in importance from one situation to another. The process involves painting a picture in each individual case. As Vinelott J said in Walls v Sinnett (Inspector of Taxes)[1986] STC 236 at 245: “It is, in my judgment, impossible in a field where a very large number of factors have to be weighed to gain any real assistance by looking at the facts of another case and comparing them one by one to see what facts are common, what are different and what particular weight was given by another tribunal to the common facts. The facts as a whole must be looked at, and a factor which may be compelling in one case in the light of the facts of that case may not be compelling in the context of another case.”” 37. In other words, the relevant court or tribunal must eschew the purely mechanical exercise of running through items on a checklist and instead stand back and make an informed, considered, qualitative appreciation of the whole. In doing so, as Vinelott J observed in Walls v Sinnet[1987] STC 236 at page 245F, because each case turns on its own specific facts, no assistance is gained by comparing the facts in one case with the facts in another because the facts that may be compelling in one case may not be compelling in the context of another. 38. In that regard, Nolan LJ in Hall noted that the test which had been applied in many cases, of whether the individual in question was carrying on business on his own account, “may be of little assistance in the case of one carrying on a profession or vocation .”
“ A self-employed author working from home or an actor or a singer may earn his living without any of the normal trappings of a business. For my part I would suggest there is much to be said in these cases for bearing in mind the traditional contrast between a servant and an independent contractor. The extent to which the individual is dependent upon or independent of a particular pay master for the financial exploitation of his talents may well be significant .” 39. Secondly, in the context of a person whose work involves a series of engagements with different end users, the judgment of Nolan LJ in Hall is again instructive. In discussing whether it was still appropriate following a change in law in 1956 to regard a contract of employment as being analogous to a contract giving rise to a “post”, as had been held by Rowlatt J in Davies v Braithwaite[1931] 2 KB 628 (“ Davies ”), Nolan LJ agreed that “ Rowlatt J’s conception of a “post”, if by that is meant something which could be filled by successive holders, is therefore no longer a helpful analogy in deciding whether or not an employment exists. But his judgment continued: 'When a person occupies a post resting on a contract, and if then that is employment as opposed to a mere engagement in the course of carrying on a profession, I do not think that is a very difficult term of distinction, though perhaps a little difficult to apply to all cases. But I would go further than that and say that it seems to me that where one finds a method of earning a livelihood which does not consist of the obtaining of a post and staying in it, but consists of a series of engagements and moving from one to the other—and in the case of an actor's or actress's life it certainly involves going from one to the other and not going on playing one part for the rest of his or her life, but in obtaining one engagement, then another, and a whole series of them—then each of those engagements cannot be considered an employment, but is a mere engagement in the course of exercising a profession, and every profession and every trade does involve the making of successive engagements and successive contracts and, in one sense of the word, employments. In this case I think it is quite clear that the respondent must be assessed to income tax under Sch. D, because here she does not make a contract with a producer for a post. She makes a contract with a producer for the next thing that she is going to do, and then with another producer, and then a third producer, and at any time she may make a record for a gramophone company or act for a film. I think that whatever she does and whatever contracts she makes are nothing but incidents in the conduct of her professional career.' In Fall v Hitchen at page 295 of the report Sir John Pennycuick quoted that passage and continued: 'In that judgment, Rowlatt J holds that the word “employment” means a post, and distinguishes it from a succession of engagements made in the course of carrying on a profession. He then goes on to hold that, on the particular facts of that case, Miss Braithwaite did not hold any post and that none of her particular engagements could be treated as a post, but that on the contrary all her successive engagements must be treated as incidents in the conduct of her profession. The learned judge nowhere says that if an actor enters into a contract in such terms as to amount to what he calls a post, then that actor is not chargeable under Sch E but under Sch D. On the contrary, it is implicit in the whole of his judgment, it seems to me, that if a professional person, whether an actor or anybody else, enters into a contract involving what the learned judge calls a post, then that person will be chargeable in respect of the income arising from the post under Sch E notwithstanding that he is at the same time carrying on his profession, the income of which will be chargeable under Sch D. The instance of a musician puts that point very neatly. I do not think that most people today would use the word “post”, which does not seem very apt to cover the countless instances of employment in the sense of a contract of service; but every word of that judgment is applicable as between the carrying on of a profession and an engagement in the course of carrying on that profession, on the one hand, and a contract of employment, on the other hand.' With those words of Pennycuick V-C I would respectfully agree...” 40. It is clear from these words that a worker whose working life generally involves entering into a series of engagements in the course of self-employment is not precluded from being regarded as an employee in relation to one of those engagements if the terms of that one engagement are more consistent with the worker’s being an employee. In Fall v Hitchen[1973] 1 WLR 286 (“ Fall ”), a taxpayer who generally carried on business on his own account as a dancer and entered into a contract with Sadler’s Wells as an interim measure was held to have been an employee under that contract. 41. Whilst the circumstances in Fall involved successive engagements, the same is also true in relation to engagements which are concurrent. Thus, it does not automatically follow that just because, at any particular time, a worker’s engagements with end users generally amount to self-employment, the relevant worker’s engagement with a particular end user cannot amount to an employment contract, and vice versa. For example, in Sidey v Phillips[1987] STC 87 , the taxpayer’s income from carrying on his profession as a barrister was taxable under Schedule D as income from self-employment but his fees from part-time lecturing were held to constitute employment income. 42. Thirdly, a statement in a contract disavowing any intention to create a relationship of employment cannot prevail over the true legal effect of the agreement – see the judgment of Henderson J in Dragonfly Consultancy Ltd v The Commissioners for Her Majesty’s Revenue and Customs[2008] EWHC 2113 (Ch) (“ Dragonfly ”). Henderson J noted that, as had previously been stated in, for example, Ready Mixed Contract (South East) Ltd v Minister of Pensions and National Insurance[1968] 2 QB 497 (“ RMC ”), in borderline cases, a statement as to the parties’ intentions might help to tip the balance one way or another but, in the vast majority of cases, this was not the case. He added that, in a case such as the one he was considering (which also concerned a services company providing the services of the worker to the end user), such a statement was even less likely to be relevant because the tripartite nature of the arrangement meant that one was necessarily constructing the terms of the hypothetical contract between the end user and the worker and not considering the terms of an actual agreement. But he went on: “ 55. I would not, however, go so far as counsel for HMRC who submitted that, as a matter of law, the hypothetical contract required by the IR35 legislation must be constructed without any reference to the stated intentions of the parties. If the actual contractual arrangements between the parties do include statements of intention, they should in my view be taken into account, and in a suitable case there may be material which would justify the inclusion of such a statement in the hypothetical contract. Even then, however, the weight to be attached to such a hypothetical statement would in my view normally be minimal, although I do not rule out the possibility that there may be borderline cases where it could be of real assistance.”
“A contract of service exists if these three conditions are fulfilled. (i) The servant agrees that, in consideration of a wage or other remuneration, he will provide his own work and skill in the performance of some service for his master. (ii) He agrees, expressly or impliedly, that in the performance of that service he will be subject to the other's control in a sufficient degree to make that other master. (iii) The other provisions of the contract are consistent with its being a contract of service. I need say little about (i) and (ii). As to (i). There must be a wage or other remuneration. Otherwise there will be no consideration, and without consideration no contract of any kind. The servant must be obliged to provide his own work and skill. Freedom to do a job either by one's own hands or by another's is inconsistent with a contract of service, though a limited or occasional power of delegation may not be: see Atiyah's Vicarious Liability in the Law of Torts (1967) pp. 59 to 61 and the cases cited by him. As to (ii). Control includes the power of deciding the thing to be done, the way in which it shall be done, the means to be employed in doing it, the time when and the place where it shall be done. All these aspects of control must be considered in deciding whether the right exists in a sufficient degree to make one party the master and the other his servant. The right need not be unrestricted. "What matters is lawful authority to command so far as there is scope for it. And there must always be some room for it, if only in incidental or collateral matters." - Zuijs v. Wirth Brothers Proprietary, Ltd . To find where the right resides one must look first to the express terms of the contract, and if they deal fully with the matter one may look no further. If the contract does not expressly provide which party shall have the right, the question must be answered in the ordinary way by implication. The third and negative condition is for my purpose the important one, and I shall try with the help of five examples to explain what I mean by provisions inconsistent with the nature of a contract of service. (i) A contract obliges one party to build for the other, providing at his own expense the necessary plant and materials. This is not a contract of service, even though the builder may be obliged to use his own labour only and to accept a high degree of control: it is a building contract. It is not a contract to serve another for a wage, but a contract to produce a thing (or a result) for a price. (ii) A contract obliges one party to carry another's goods, providing at his own expense everything needed for performance. This is not a contract of service, even though the carrier may be obliged to drive the vehicle himself and to accept the other's control over his performance: it is a contract of carriage. (iii) A contract obliges a labourer to work for a builder, providing some simple tools, and to accept the builder's control. Notwithstanding the obligation to provide the tools, the contract is one of service. That obligation is not inconsistent with the nature of a contract of service. It is not a sufficiently important matter to affect the substance of the contract. (iv) A contract obliges one party to work for the other, accepting his control, and to provide his own transport. This is still a contract of service. The obligation to provide his own transport does not affect the substance. Transport in this example is incidental to the main purpose of the contract. Transport in the second example was the essential part of the performance. (v) The same instrument provides that one party shall work for the other subject to the other's control, and also that he shall sell him his land. The first part of the instrument is no less a contract of service because the second part imposes obligations of a different kind: Amalgamated Engineering Union v. Minister of Pensions and National Insurance . I can put the point which I am making in other words. An obligation to do work subject to the other party's control is a necessary, though not always a sufficient, condition of a contract of service. If the provisions of the contract as a whole are inconsistent with its being a contract of service, it will be some other kind of contract, and the person doing the work will not be a servant. The judge's task is to classify the contract (a task like that of distinguishing a contract of sale from one of work and labour). He may, in performing it, take into account other matters besides control.” 45. It has been said in later cases that the first two conditions set out above amount to an “irreducible minimum by way of legal requirement for a contract of employment to exist ” (see Buckley J, Longmore LJ and Brooke LJ in Montgomery v Johnson Underwood Ltd and another[2001] ICR 819 (“ Montgomery ”) at paragraphs [23], [46] and [47] and Stephenson LJ in Nethermere (St Neots) Ltd v Gardiner [ 1984] ICR 612 at page 623). Mutuality of obligation 46. The first of MacKenna J’s three conditions is commonly termed “ mutuality of obligation ”
“ The BBC will not be obliged to call on the [services] of [Ms Adams] or to use any of the [contributions], and will not be liable to the [Appellant] or to [Ms Adams] for any loss or damage or any failure to obtain publicity or any opportunity to enhance the reputation of [Ms Adams], as a result provided that the BBC will still be obliged to pay the [Minimum Fee] (subject to any other provisions in the [agreement] to the contrary)”, (clause 14 of Part B); (r) it provided expressly that the failure of either party to the agreement to exercise or enforce any right conferred on it by the agreement “ will not be deemed to be a waiver of any such right or operate so as to bar the exercise or enforcement of such right at any time thereafter ” and that no omission or delay on the part of any party to the agreement in exercising any right or discretion under the agreement would “ operate as a waiver by it of any such right or stop the exercise or enforcement of any such right at any time thereafter ” (clauses 16.1 and 16.2 of Part B); (s) it precluded the Appellant from assigning or sub-contracting its rights under the agreement but stated that the Appellant “ will be entitled to nominate and provide an alternative Contributor in exceptional circumstances where [Ms Adams] is not available for reasons beyond [her] reasonable control (not including suspension hereunder) subject to reasonable prior notice being given to the [BBC] and such alternative provider being deemed suitable and being approved by the [BBC] for this purpose. The terms of this [agreement] will remain in effect in relation to the substitute for the approved duration of their services ” (clause 16.7 of Part B); and (t) it specified that no amendment to the terms of the agreement “ will be valid or binding unless made by prior written [contract] between the parties and signed by them or their authorised representatives” (clause 16.7 of Part B) and that the agreement would “ prevail at all times over all other terms and conditions which may purport to apply in connection with the [services], unless amended by the prior written agreement of the parties…” (clause 16.10 of Part B). 56. Now that we have summarised the material terms of the written agreements, we turn to the evidence which was provided by the witnesses. We consider that it is not necessary to summarise the contents of either the Correspondence or the notes of the meeting held between the Respondents and the BBC on27 September 2016 because the ground covered by the Correspondence and those notes was largely repeated in the witness evidence. Where a specific extract from that material is pertinent to the evidence given by a witness, we will refer to it in our summary of the relevant witness’s evidence. The witness evidence 57. The material parts of Ms Adams’s evidence may be summarised as follows: (a) Ms Adams has been a freelance journalist for more than 20 years. Over that period, she has provided her services to a wide variety of media organisations, including the BBC, and she has never over that period received, from any of the organisations to whom she has provided her services, any employment-related benefits such as holiday and sick pay, maternity leave or a pension entitlement; (b) she was first approached by Mr Jeff Zycinski, the head of radio at BBC Scotland, in 2010 to host a morning radio phone-in and she has worked for the BBC since that date although the number of weekly programmes and the duration of those programmes have fluctuated over that period and she has provided her services under a series of agreements, each of which has a term of around one year; (c) if she was unable to fulfil the Minimum Commitment because of her own unavailability, then the Minimum Fee would be reduced by a pro rata amount. She had not really contemplated what the position would be if her failure to fulfil the Minimum Commitment was attributable to a failure by the BBC to call on her services despite the fact that she was available. (In that regard, her answer to question 43 in the Correspondence suggested that she would have expected a similar reduction to the Minimum Fee in that instance whereas both the Respondents’ and the BBC’s notes of the meeting of27 September 2016 between the Respondents and the BBC recorded a response to the contrary from Alison Denver of the BBC’s legal and business team, at least in relation to an earlier agreement than the ones which are at issue in the appeal;) (d) for each programme, she would receive a briefing note by email on the evening before the programme and would spend between 20 minutes and 2 hours during the evening working on the content and writing the script. She would then send that to the producer later in the evening so that the producer was able to put it onto the BBC’s system. This was essential to the whole team’s having access to the script whilst she was on air. In the morning, the rest of the team would be in before her arrival at around 7.15 to 7.30 and would have worked on the material during that time. There would then be a team discussion before the final content of the programme was agreed, shortly before 9 am; (e) whilst on air, she would have ultimate control over which callers to take, what questions to ask and what direction the show should follow although other members of the team would make suggestions in that regard; (f) at the end of each programme, she would spend a short time with the team debriefing on how the programme had gone and then having preliminary discussions with the team for the following day’s programme in relation to the content of that programme, before leaving the BBC at around 12.30; (g) as a result of her parents’ ill-health and her responsibilities to her children over the tax years of assessment in question, she had not managed to fulfil the Minimum Commitment under at least one of the two agreements which were pertinent to the appeal and had not been paid a proportionate part of the Minimum Fee under that agreement as a result; (h) none of the agreements which were pertinent to the appeal had been reviewed by her agent because she saw no need to pay an agency commission in respect of them, given that her earlier agreements with the BBC had been negotiated by her agent; (i)during the term of one of those earlier agreements (in 2011), she had put out a tweet from her own personal twitter account in relation to the then London Mayor, Boris Johnson. The BBC considered that the tweet was in breach of the Standards and she was suspended for 3 weeks as a result. The BBC did not pay her for the programmes which she had missed during the period of her suspension; (j)she was very conscious of the need to maintain a high personal profile in order to maximise her income. Accordingly, she had spent a lot of time developing her own brand through her work for other media outlets, her hosting of events and awards and her social media output. She currently had around 133,000 followers. Her work on Loose Women was particularly significant in that regard because it meant that her face was recognised more widely. Accordingly, she had tended to cut back on her work for the BBC whenever she had been given an opportunity to expand her work on Loose Women. Whenever she was introduced on stage at her other engagements, she was more likely to be referred to as “Loose Women’s Kaye Adams” than as “the BBC’s Kaye Adams”; (k) the significance to her of her own brand development could be seen when she was criticised by certain women’s organisations for her handling of a debate on the case of Ched Evans, a footballer who had been accused of rape and was ultimately acquitted. Although the BBC did not consider that her handling of the debate amounted to a breach of her agreement with them, she felt that the criticism was unfair and would have a detrimental impact on her reputation if left unchallenged. Accordingly, she had, of her own initiative and at her own expense, sought to challenge the criticism by submitting a complaint to the Press Commission; (l)the BBC never sought to place any restrictions on her work for others and it was at all times understood by the BBC that she would continue to carry on with her other engagements without seeking the BBC’s permission. In fact, the BBC would often go out of its way to help her to fulfil her other engagements by allowing her to present her programme from an alternative location. This suited the BBC as well because the higher her national profile, the better it was for the BBC too. Having said that, in the course of her regular and ongoing discussions with other members of the team, she would often tell them what she was planning to do – not by way of seeking permission for her other work but merely to solicit their thoughts on her other engagements and to bounce ideas back and forth. She would not have felt constrained from accepting another engagement merely because she had not mentioned it to the BBC team in one of those discussions; (m) she did not have access to the BBC operating system when she was working from home and would therefore use her own mobile phone, computer and personal email address to communicate with the BBC during those times. In addition, on those occasions when the programme was broadcast from outside the studio and the technology provided at the relevant location was insufficient, she would use her own equipment – an IPad and a mobile phone – to present the programme; (n) she had been given a copy of the Guidelines when she first started to work for the BBC but she couldn’t say that she had ever read them or referred to them on any occasion. On reading them recently as a result of the present dispute, they appeared to encapsulate what she would have regarded as good practice which she would have chosen to follow in any event. She could not recall the BBC’s personnel’s ever raising with her in relation to one of her programmes the BBC’s duties under the Guidelines although, had they done so, she would have taken the matter seriously as it was not in her interests to breach the Guidelines, both in terms of her ongoing relationship with the BBC and in relation to her other engagements and her profile and brand in general; (o) she observed that, had she wanted to breach the Guidelines whilst on air, the BBC would have been unable to stop her as she had control of the microphone but she conceded that the BBC would then have been able to discipline her, either by suspending her (as it had done in relation to the Boris Johnson tweet) or by terminating the agreement between the BBC and the Appellant; (p) apart from the Boris Johnson-related suspension, the BBC had never sought to control the content of her social media output or her articles for newspapers. In addition, she had been an ambassador for breast cancer and children’s charities and the BBC had never sought to intervene in that; (q) her work for the BBC during the two tax years of assessment in question had been no different in terms of content or approach from her work for the BBC in the earlier tax years of assessment which were also the subject of the Determination and the Notice and the appeal in relation to which the Respondents had now agreed not to oppose. In fact, she had at one stage in the earlier tax years of assessment been presenting her programme on the BBC for five days each week and not four. The only difference was that, in the two tax years of assessment which remained the subject of the appeal, she had done a greater percentage of her overall work for the BBC than for others. The reason for this was that, because of her father’s illness, she was keen to spend as much of her working time as possible in the Glasgow area and to reduce her travelling so that she could spend time with him in her afternoons; (r) she would frequently record promotions for the programme – these would generally be recorded just after she arrived at the studio in the morning and would appear on BBC Scotland TV. This was in her interests, as well as the BBC’s, and so there was no need for the BBC to compel her to do it; (s) she had not read the written agreements which were relevant in this case as she knew what she had agreed in her discussions with Mr Zycinski and she had worked for the BBC for a number of years already; (t) she accepted that the only one of the services outlined in clause 3.1 of the written agreements which could realistically be performed by a substitute might be the preparation for a programme (see clause 3.1.1). This was consistent with her response to question 54 in the Correspondence – which asked whether Ms Adams was entitled to send a replacement to carry out her work under the written agreement - to which Ms Adams had replied “ Of course not ”; and (u) notwithstanding the terms of each written agreement, she had not been asked by the BBC to complete any editorial training or to undergo a medical. 58. The material parts of Mr Paterson’s evidence may be summarised as follows: (a) he confirmed that he was the editor in charge of the Kaye Adams Programme in the period from April 2015 until December 2016 and his description of the manner in which each day’s programme was put together was consistent with the description of that process by Ms Adams; (b) he reiterated the collaborative approach which was adopted by the whole team associated with the programme and said that, given that that was the case, there was no need for the editorial team ever to insist on editorial control over the programme’s content. Instead, the team, together with Ms Adams, would discuss the content of each programme and decide together on the format. Ms Adams, as an experienced journalist, was at the forefront of such discussions. Reference was made to the BBC’s note of the meeting of27 September 2016 in which Mr Paterson had likened Ms Adams to the conductor of “ her Orchestra ”
“ On the other hand, it does not apply when the intention of the parties, objectively ascertained, has to be gathered partly from documents but also from oral exchanges and conduct. In the latter case, the terms of the contract are a question of fact. And of course the question of whether the parties intended a document or documents to be the exclusive record of the terms of their agreement is also a question of fact ” (see Carmichael at page 1233B). 78. In Carmichael , the House of Lords held that it was permissible for the industrial tribunal in that case to have taken into account, in determining the terms of the agreement in that case, the belief and conduct of the parties to the agreement and that this was a question of fact and not law. Lord Hoffman noted: “In a case in which the terms of the contract are based upon conduct and conversations as well as letters, most people would find it very hard to understand why the tribunal should have to disregard the fact that Mr Lovatt and Mrs Carmichael both agreed that the CEGB were under no obligation to provide work and the respondents under no obligation to perform it. It is, I think, pedantic to describe such evidence as mere subjective belief. In the case of a contract which is based partly upon oral exchanges and conduct, a party may have a clear understanding of what was agreed without necessarily being able to remember the precise conversation or action which gave rise to that belief. As the Court of Appeal pointed out, the tribunal did not make any specific findings about what was said at the interviews or on any other occasion. But the terms of the engagement must have been discussed, and these conversations must have played a part in forming the views of the parties about what their respective obligations were. The evidence of a party as to what terms he understood to have been agreed is some evidence tending to show that those terms, in an objective sense, were agreed. Of course the tribunal may reject such evidence and conclude that the party misunderstood the effect of what was being said and done. But when both parties are agreed about what they understood their mutual obligations (or lack of them) to be, it is a strong thing to exclude their evidence from consideration. Evidence of subsequent conduct, which would be inadmissible to construe a purely written contract (see James Miller & Partners Ltd v Whitworth Street Estates (Manchester) Ltd [1970 1 All ER 796,[1970] AC 583 may be relevant on similar grounds, namely that it shows what the parties thought they had agreed. It may of course also be admissible for the same purposes as it would be if the contract had been in writing, namely to support an argument that the terms have been varied or enlarged or to found an estoppel” (see Carmichael at page 1234F). 79. In Carmichael , the written terms of the agreement between the parties were incomplete and ambiguous. In addition, they had been drafted by a lay person and the evidence of the parties as to what they understood to have been agreed was not directly contrary to those written terms. It is therefore not surprising that the House of Lords held that the evidence of the parties as to their understanding of the agreement between them was highly relevant in determining the terms of that agreement and that that determination was a question of fact and not law. In the words of Lord Irvine in Carmichael , the parties in that case did not intend the written agreement “ to constitute an exclusive memorial of their relationship ” (see Carmichael at page 1231A). 80. In contrast, the present case involves circumstances where the terms of each written agreement do purport to be a complete record of the actual agreement between the parties. It is therefore distinguishable from Carmichael . Nevertheless, it is plain from the lengthy extract from Lord Clarke’s decision in Autoclenz set out in paragraph 26 above that, in the case of a contract concerning work and services, the same principle applies in determining whether a term set out in a written agreement accurately reflects the agreement between the parties. In other words, it is necessary for the relevant tribunal or court to determine, as a question of fact, whether the written agreement between the parties accurately reflects the actual agreement between the parties. 81. It follows that, before we can address the question of law which is at the centre of this case – which is to say, whether the hypothetical contract constructed out of each actual agreement between the BBC and the Appellant is a contract for services or a contract of service - we need to determine, as a question of fact, whether the terms of each written agreement between the BBC and the Appellant accurately reflected the related actual agreement between those companies. It is to that question which we now turn. Our findings of fact 82. Each of the findings of fact set out below has been made on the balance of probabilities. 83. Our task in finding the facts has been rendered more difficult by the fact that: (a) unfortunately, we were not provided with any evidence from Mr Jeff Zycinski – the head of radio at BBC Scotland who initiated, and then conducted on behalf of the BBC, the discussions between the BBC and Ms Adams which led to her presenting the programme – anyone from the BBC’s legal and business affairs team – which was responsible for sending each written agreement to Ms Adams – or anyone from the BBC’s business management team – which was responsible for keeping a record of the number of programmes which had been presented by Ms Adams during the period of each written agreement. It would have been helpful in particular to have heard from the member of the BBC’s legal and business affairs team who was responsible specifically for dealing with the two written agreements in this case; and (b) as both Mr Paterson and Ms Adams were keen to stress, production of Ms Adams’ programme was very much a collaborative effort in which the interests of the BBC and Ms Adams were generally very closely aligned. There was thus very little reason for either party to each actual agreement between the BBC and the Appellant to seek to rely on its rights under the relevant agreement. In virtually all cases, any disagreement between the parties could be solved by discussion and without recourse by either party to the relevant agreement of its rights under the relevant agreement. 84. Nevertheless, in addition to being taken through the terms of the written agreements, we have had the benefit of hearing and/or reading the witness evidence of Mr Paterson and Mr Hollywood and the shortcoming noted in paragraph 83(a) above has largely been alleviated by that evidence. In particular, the written and oral testimony of Mr Paterson, who was closely involved with the making of the programme and therefore had a sound knowledge of how the relationship between the BBC and Ms Adams operated in practice, was of considerable assistance to us in determining the terms of each actual agreement between the BBC and the Appellant. First call and control over other engagements 85. In determining the terms of each actual agreement between the BBC and the Appellant, a significant point of difficulty lies in trying to distinguish between, on the one hand, a right which exists under the terms of each such agreement but has never been exercised and, on the other hand, a right which does not exist under the terms of each such agreement. The Respondents say that, if it is necessary to determine which of those two categories a right which appears in the written agreement between the BBC and the Appellant falls within, then the right in question must fall within the first category as long as the right is not a sham and is one which the BBC might reasonably have been expected to want. However, as we have already concluded in paragraphs 22 to 33 above, the Supreme Court decision in Autoclenz demonstrates that the correct approach to this question is more nuanced than that. In such a case, the mere fact that the right appears in the written agreement, is not a sham and is one which the BBC might reasonably have been expected to want is not enough for the right to fall within the first category if the evidence as a whole shows that the right in fact falls within the second category. 86. It is inevitably difficult to distinguish evidence suggesting that a right falls within the first category from evidence suggesting that the right falls within the second category, since the same evidence can often indicate that either is the case. In other words, the fact that the parties to a written agreement have not adhered strictly to the terms of that written agreement might mean that that written agreement does not reflect the terms of the actual agreement between them but it might also mean that one party has decided not to enforce its rights under the actual agreement between them. Determining which of those is the case is by no means straightforward. However, it is a task which we must undertake in order to determine the relevant facts in this case. 87. A striking feature of the present circumstances is that, whilst each written agreement specified that the BBC had first call on Ms Adams’s time during the term of the agreement and that Ms Adams was required to obtain the BBC’s permission in advance of entering into any other engagements during the term of the agreement, both Ms Adams and Mr Paterson were clear that neither of these was the case. The evidence of both Ms Adams and Mr Paterson was to the effect that the BBC simply did not have the right of first call on Ms Adams’s time or the right to control Ms Adams’s other engagements. It was not to the effect that the BBC had those rights but chose not to exercise them. In this regard, see paragraphs 57(l) and (p) and paragraph 58(e) above. 88. Indeed, the evidence we heard suggested that the BBC took steps to accommodate Ms Adams’s other engagements when it could – for example, by agreeing to her presenting the programme from outside the studio when that was required by Ms Adams’s other commitments – see paragraph 57(l) above. Thus, the evidence of Ms Adams was that, far from being entitled to compel her to refuse her other engagements on the basis both that it had first call on her time and that Ms Adams required its permission to enter into those other engagements, the BBC did whatever it could to accommodate those other engagements. 89. In addition, although Ms Adams accepted that the BBC could penalise Ms Adams retrospectively by suspending, or, in a severe case, terminating, the actual agreement between the BBC and the Appellant if it considered that the content of any of Ms Adams’s other engagements brought the BBC into disrepute or could result in the BBC’s suffering OFCOM sanctions, both Ms Adams and Mr Paterson said that the BBC did not have any right to control that content – for example, by requiring Ms Adams to submit it to the BBC for approval in advance. In this regard, see paragraphs 57(i) and (p) and paragraph 58(e) above. 90. The position summarised in paragraphs 87 to 89 above is contrary to various express terms of each written agreement between the BBC and the Appellant. However, Ms Adams testified that she had no knowledge of the terms of each written agreement and had had no negotiations on those terms with the BBC legal and business affairs department. As far as she was concerned, she had reached an understanding with Mr Zycinski as to the nature of the arrangement between the BBC and the Appellant and she, not unnaturally, considered that both he, as the representative of the BBC and she, as the representative of the Appellant, knew what they had agreed. Thus, although she signed each written agreement, she candidly admitted that she did not know what the written agreements said. In this regard, see paragraphs 57(h) and (s) and paragraph 58(d) above. 91. In the light of the principles set out by Lord Clarke in Autoclenz , as discussed in paragraphs 22 to 33 above, we need to determine, in the light of all the evidence, whether the terms of each actual agreement between the BBC and the Appellant entitled the BBC to have the right of first call on Ms Adams’s time and to control the nature and content of her other engagements (albeit that the BBC chose not to exercise those rights) or whether, on the contrary, the BBC had no such rights. The evidence which we need to consider in that regard includes both the terms of each written agreement and the witness evidence which has been presented to us. 92. In conducting that exercise so far as the right to first call on Ms Adams’s time and the right of control over Ms Adams’s other engagements are concerned, we have taken into account both the express terms to that effect in each written agreement and the fact that the terms of clause 16.10 of Part B of each written agreement stipulated that “ [this] contract will prevail at all times over all other terms and conditions which may purport to apply in connection with the Services, unless amended by the prior written agreement of the parties…”