In (1) Clark v Bexley Heath Authority and Secretary of State for Health and (2) Enderby v Frenchay Health Authority and Secretary of State for Health (1.2.89) EOR24E, a London South industrial tribunal holds that the employers had established a material factor defence within the meaning of s.1(3) of the Equal Pay Act 1970 by showing that the variation in pay between NHS speech therapists and their comparators, pharmacists and clinical psychologists, was due to historical differences in the bargaining structures.
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