Ms Vicki Barnard v Hampshire Fire and Rescue Authority (operating a Service) — 2018

At a preliminary hearing in Southampton on 8-9 May 2018, Employment Judge Kolanko considered only whether Ms Vicki Barnard's equal pay complaints were in time under sections 129 and 130 of the Equality Act 2010. The tribunal addressed whether there had been a stable working relationship across her moves from station administrator to Business Support Officer, then to Fire Safety Officer, then to Office Manager, and finally to Community Safety Delivery Manager.

Applying the approach in Preston, Slack, North Cumbria and Dass, the tribunal held that the move from Business Support Officer to Fire Safety Officer ended the stable working relationship because the roles differed in pay, enforcement powers and responsibilities, and that the move from Fire Safety Officer to Office Manager was also a significant change because it introduced managerial duties, including supervision of Fire Safety Officers. The complaints relating to the Business Support Officer and Fire Safety Officer periods were therefore out of time and dismissed.

By contrast, the tribunal found that the move from Office Manager to Community Safety Delivery Manager did not interrupt the stable working relationship. It accepted that the claimant was doing the same work and treated the merger of the two departments as a minor difference, reinforced by the line manager's view of the claimant's competence and the later backdated pay adjustment. The complaint relating to the Office Manager role was therefore held to be in time, but the merits of any equal pay issue were not determined in this judgment.