Network Rail Infrastructure Ltd v Crawford [2019] EWCA Civ 269 (05 March 2019)

Network Rail Infrastructure Ltd v Crawford [2019] EWCA Civ 269 (05 March 2019)

Compensatory rest under regulation 24(a) of the Working Time Regulations 1998 does not require an uninterrupted period of at least 20 minutes; discontinuous breaks aggregating to 20 minutes can satisfy the requirement if they provide equivalent benefit to the worker's well-being.

Citation
[2019] EWCA Civ 269
Parties
Appellant: Network Rail Infrastructure Ltd; Respondent: David Crawford
Jurisdiction
England and Wales
Judgment Date
05 March 2019
Procedural Posture
Employment Appeal / Court of Appeal Judgment
Outcome
Appeal allowed; Employment Tribunal's dismissal of the claim restored.
Legal Topics
Working Time Regulations, Rest Breaks, Compensatory Rest, Railway Transport Workers
Employment Law Health and Safety Law Working Time Regulations Rest Breaks Compensatory Rest Railway Transport Workers

Case Brief

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Parties

Network Rail Infrastructure Ltd

Appellant

David Crawford

Respondent

Procedural Posture

Employment Appeal / Court of Appeal Judgment

Legal Issues

  1. 1 Whether compensatory rest under regulation 24(a) of the Working Time Regulations 1998 must be an uninterrupted period of at least 20 minutes
  2. 2 Whether discontinuous breaks aggregating to 20 minutes satisfy regulation 24(a)
  3. 3 Whether the employer refused to permit the claimant to exercise his right to compensatory rest

Ratio Decidendi

Compensatory rest under regulation 24(a) of the Working Time Regulations 1998 does not require an uninterrupted period of at least 20 minutes; discontinuous breaks aggregating to 20 minutes can satisfy the requirement if they provide equivalent benefit to the worker's well-being.

Court Disposition

Appeal allowed; Employment Tribunal's dismissal of the claim restored.

Orders

  • The appeal is allowed.
  • The Employment Tribunal's decision dismissing the claim is restored.