Coats UK Pension Scheme Trustees Ltd v Styles & Ors

Coats UK Pension Scheme Trustees Ltd v Styles & Ors

The 2008 Deed validly modified Rule 17.6 of the 2004 Rules under section 68 of the Pensions Act 1995, thereby limiting annual pension increases to the higher of 3% or RPI and removing entitlement to 5% increases from 4 February 2008. The deed was not invalidated by accrued rights protections or the Transfer Agreement.

Parties
Appellant: Coats UK Pension Scheme Trustees Limited; First Respondent: Alan Roland Styles; Second Respondent: Roderick Donald Armitage; Third Respondent: Richard Edward Brown
Jurisdiction
England and Wales
Judgment Date
14 January 2019
Procedural Posture
Appeal / Judgment
Outcome
Appeal allowed
Legal Topics
Modification of Pension Scheme Rules, Accrued Rights, Statutory Powers, Interpretation of Trust Deeds, Transitional Provisions
Pensions Trusts Employment Modification of Pension Scheme Rules Accrued Rights Statutory Powers Interpretation of Trust Deeds Transitional Provisions

Case Brief

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Parties

Coats UK Pension Scheme Trustees Limited

Appellant

Alan Roland Styles

First Respondent

Roderick Donald Armitage

Second Respondent

Richard Edward Brown

Third Respondent

Procedural Posture

Appeal / Judgment

Legal Issues

  1. 1 Whether respondents are entitled to annual pension increases of 5% after 4 February 2008
  2. 2 Effectiveness and validity of the 2008 Deed under section 68 of the Pensions Act 1995
  3. 3 Interpretation of scheme rules and Inland Revenue Limits

Ratio Decidendi

The 2008 Deed validly modified Rule 17.6 of the 2004 Rules under section 68 of the Pensions Act 1995, thereby limiting annual pension increases to the higher of 3% or RPI and removing entitlement to 5% increases from 4 February 2008. The deed was not invalidated by accrued rights protections or the Transfer Agreement.

Court Disposition

Appeal allowed

Orders

  • Respondents are not entitled to annual pension increases of 5% from 4 February 2008.
  • Annual increases are limited to the higher of 3% or RPI as per Rule 17.6 of the 2004 Rules as modified by the 2008 Deed.