Network Rail Infrastructure Ltd v Crawford

Network Rail Infrastructure Ltd v Crawford

An equivalent period of compensatory rest under regulation 24(a) of the Working Time Regulations 1998 does not have to be a single uninterrupted 20-minute break; it can be satisfied by aggregated shorter breaks if, in the tribunal's judgment, they are equivalent in value to the worker's well-being given the nature of the work.

Parties
Appellant: Network Rail Infrastructure Ltd; Respondent: David Crawford
Jurisdiction
England and Wales
Judgment Date
05 March 2019
Procedural Posture
Appeal / Court of Appeal Judgment
Outcome
Appeal allowed; Employment Tribunal's decision restored; claim dismissed.
Legal Topics
Working Time Regulations, Rest Breaks, Compensatory Rest, Employment Tribunal Procedure
Employment Law Labour Law Working Time Regulations Rest Breaks Compensatory Rest Employment Tribunal Procedure

Case Brief

Summary, issues, holding and outcome

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Parties

Network Rail Infrastructure Ltd

Appellant

David Crawford

Respondent

Procedural Posture

Appeal / Court of Appeal Judgment

Legal Issues

  1. 1 Whether compensatory rest under regulation 24(a) of the Working Time Regulations 1998 must be a single uninterrupted period of at least 20 minutes or can be satisfied by aggregated shorter breaks.
  2. 2 Whether the Employment Appeal Tribunal was correct in holding that only an uninterrupted 20-minute break satisfies the requirement for compensatory rest.
  3. 3 Whether Network Rail refused to permit the claimant to exercise his right to compensatory rest.

Ratio Decidendi

An equivalent period of compensatory rest under regulation 24(a) of the Working Time Regulations 1998 does not have to be a single uninterrupted 20-minute break; it can be satisfied by aggregated shorter breaks if, in the tribunal's judgment, they are equivalent in value to the worker's well-being given the nature of the work.

Court Disposition

Appeal allowed; Employment Tribunal's decision restored; claim dismissed.

Orders

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