[2007] EWCA Civ 19, Court of Appeal on 24th January 2007, reported at [2007] ICR 983 (also at [2007] IRLR 440).



Authority for the proposition that:-

an employer's failure to fulfil an alleged promise to provide a share bonus scheme is not covered by the unlawful deduction from wages provision of Part II of the Employment Rights Act 1996 (notably in this context ERA 1996 s.13) because those provisions apply only where there is a claim for an identifiable sum capable of quantification. Overruling an earlier decision of the EAT, the Court of Appeal held that therefore an employment tribunal has no jurisdiction in this context and that a claim of this nature can only proceed as a breach of contract action in the County Court or High Court.

For relevant general notes see Deductions from wages etc/jurisdiction of Employment Tribunals

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