MBL UK Ltd v Quigley - Non-provision of training precluded operation of "claw-back" clause to cover costs of such training [2009] EAT

"Claw-back" on dismissal of training costs amounted to unlawful deduction of wages when the training had not actually been provided. 

Mr Quigley was dismissed after working for MBL for just under 6 months. His contract contained a clause which stated that MBL would provide training during the probationary period, and would be entitled to claw back £500 from a final salary payment in the event of dismissal during that probation period, to cover training costs. MBL did this, and Mr Quigley claimed unlawful deduction from wages.