In 2015 the Claimant was offered and accepted a promoted post of Logistics Co-ordinator. A dispute arose as to whether he was entitled to receive a "Personal Differential" (PD) in addition to his full increased salary on the basis of a term in a collective agreement known as the Glasgow Forum Agreement (GFA). In 2016 he raised a claim alleging unlawful deduction of wages in terms of s13 of the ERA 1996. The ET dismissed the claim on the basis that the claimant did not have a specific contractual entitlement to a PD. The claimant appealed.

The EAT dismissed the appeal. Reading the ET judgment as a whole, there was just sufficient to convey what material parts of the evidence had been relied on for the conclusion. The substance of the rule had been complied with and the Claimant would have known why he had lost.