Dryden v Greater Glasgow Health Board [1992] IRLR 469 is a UK labour law case concerning the contract of employment. It held that a variation of company workplace customs, which are incorporated into individual contracts of employment can take place after a proper consultation without breaching employees' contracts.

Facts

Ms Dryden was a nursing auxiliary in a Glasgow

Glasgow

Glasgow is the largest city in Scotland and third most populous in the United Kingdom. The city is situated on the River Clyde in the country's west central lowlands...

 hospital

Hospital

A hospital is a health care institution providing patient treatment by specialized staff and equipment. Hospitals often, but not always, provide for inpatient care or longer-term patient stays....

. She smoked. After consultations, which she did not contribute to, smoking was banned. She claimed constructive dismissal on the basis that the workplace custom being unilaterally changed breached her employment contract.

Judgment

Lord Coulsfield held that a unilateral variation on the workplace rules did not amount to a breach of any contract term. The consultation process was influential in making the rule change legitimate.

See also

• UK labour law
• Employment contract in English law
  Employment contract in English law
  An employment contract in English law is a specific kind of contract whereby one person performs work under the direction of another. The two main features of a contract is that work is exchanged for a wage, and that one party stands in a relationship of relative dependence, or inequality of...
  
  
• Autoclenz Ltd v Belcher
  Autoclenz Ltd v Belcher
  Autoclenz Ltd v Belcher [2011] is a significant UK labour law case decided by the Supreme Court of the United Kingdom, concerning the scope of statutory protection of rights for working individuals...
  
  [2011] UKSC 41