This case revolved around the public sector pay freeze, although not to the right to impose a freeze on increases to wages per se. Rather it involved the withholding of increments or guaranteed pay progression points. The three claims here are seen as test cases for other public sector employees denied incremental rises.

Incremental increases were part of a collective agreement designed to motivate and reward longer-serving public servants. Although considered at the time of earlier pay rise negotiations, the original tribunal and the EAT found that the correct c onstruction of the agreement was that it dealt with two subjects. The first was the pay increase for staff generally, which was limited to the years 2009/10. However, there was also agreed a structural change, which introduced guaranteed pay progression points: that structural change was not limited in time to those two years.

The EAT went on to comment on the use of pay progression and the impact on the workplace and employment relations:

"... far from leading to chaos, it would tend to promote stabilit y in the employment relationship. One only has to contemplate what, for example, would happen, quite apart from the facts of the present case, in an ordinary employment situation if employees are told in an agreement that this is the pay structure to which they can look forward over many years going, well beyond the current pay round or even a two-year period as in this case. Typically, as indeed in this case, they may well expect, under the agreement which has been reached, that they will be able to look forward to an increase, for example, at the six-year point. If they are then told that actually, in the next pay round, nothing can be taken as read and everything is up for grabs once again because a pay deal has to be struck each year, or perhaps every two years, that in our judgment, would be a recipe for instability and a justifiable sense of grievance in the workplace. That is not only a point in the interests of employees. It seems to us that is a point which is in the interests of employers. After all, the reason why, as we understand it, employers tend to have pay progression structures of this kind is precisely because they wish to reward loyalty and to reward experience. Those are matters which are beneficial to the organisation and to the efficient conduct of its work."

http://bit.ly/1haX1QK