Amdocs v Langton: Court of Appeal success for Douglas Leach

Amdocs v Langton: Court of Appeal success for Douglas Leach

28 Jul, 2022

The Court of Appeal handed down its judgment in Amdocs Systems Group Ltd v Langton [2022] EWCA Civ 1027 on 22.7.22, dismissing Amdocs’ appeal.

The judgment establishes firmly that Mr Langton had a contractual entitlement to annual 5% increases in the payments due to him under a contractual income protection scheme: that entitlement was an express term of the contract, located in a “summary of benefits” appended to his offer letter, and provided to him together with a statement of terms and conditions.

The ET had rejected the argument that because the statement of terms said that the entitlement to the income protection scheme was to the extent set out in a separate “manual” and outlined in the offer letter, the summary of benefits could not be of any contractual force. No relevant manual was available in evidence in any event. It further rejected the argument that Admocs’ obligations were limited to the passing over of monies received by it from the insurer underwriting the scheme, in circumstances where it had chosen to amend its insurance policy so as to remove cover for the 5% annual escalations.

The EAT dismissed Amdocs appeal, in a judgment that attracted interest amongst employment lawyers. That judgment has now been upheld.

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Douglas Leach

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