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Crystal Palace FC Ltd & Anor v Kavanagh & Ors - Crystal Palace staff sacked for reason connected with the transfer but for ETO reason [2013] EWCA

Dismissal of staff to facilitate early sale is reason connected with the transfer

Facts: Crystal Palace at the end of the 2009-2010 season were in dire financial straits. The company which then owned them, Crystal Palace FC (2000) Limited was faced with the serious prospect of liquidation and had been put into administration on 26 January 2010. The administrator was Mr Guilfoyle. Mr Guilfoyle sought to sell the Club as a going concern. He was aware of the interest of a consortium led by Steve Parish. Any sale was bound to be complicated because Crystal Palace (2000) did not own the Selhurst Park stadium. That was owned by Selhurst Park Limited. On 12 February 2010 Selhurst Park Limited too went into administration and Price Waterhouse Coopers (PWC) were appointed administrators. Its principal creditor was its bank. Eventually, agreements were reached for the sale to the consortium. All formalities were completed by 19 August 2010, at which point the purchaser was CPFC Limited.

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