Crawford v. Network Rail Infrastructure Ltd [2017] UKEAT 0316_16_0811 (8 November 2017)

Crawford v. Network Rail Infrastructure Ltd [2017] UKEAT 0316_16_0811 (8 November 2017)

Regulation 24(a) requires, so far as possible, that compensatory rest be provided as a single uninterrupted period of at least 20 minutes. Aggregated shorter breaks do not satisfy this requirement. The employer was in breach where such a break was not provided.

Citation
[2017] UKEAT 0316_16_0811
Parties
Appellant/claimant: Mr Crawford; Respondent/employer: Network Rail
Jurisdiction
United Kingdom
Judgment Date
08 November 2017
Procedural Posture
Employment Appeal / Appeal Judgment
Outcome
Appeal allowed
Legal Topics
Working Time Regulations, Rest Breaks, Compensatory Rest, Railway Employment
Employment Law Labour Law Working Time Regulations Rest Breaks Compensatory Rest Railway Employment

Case Brief

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Parties

Mr Crawford

Appellant/claimant

Network Rail

Respondent/employer

Procedural Posture

Employment Appeal / Appeal Judgment

Legal Issues

  1. 1 Whether compensatory rest under regulation 24(a) of the Working Time Regulations 1998 must comprise a single uninterrupted period of at least 20 minutes.

Ratio Decidendi

Regulation 24(a) requires, so far as possible, that compensatory rest be provided as a single uninterrupted period of at least 20 minutes. Aggregated shorter breaks do not satisfy this requirement. The employer was in breach where such a break was not provided.

Court Disposition

Appeal allowed

Orders

  • Matter remitted to the Employment Tribunal to identify affected shifts and consider remedies.