In Hovell v Ashford and St Peter's Hospital NHS Trust  IRLR 734 CA, the Court of Appeal held that a small difference in points between a woman's job and that of her equivalently rated comparator in a job evaluation scheme does not of itself establish that the jobs are of equal value. However, where the employee's job has been marked lower than her comparator's, an employment tribunal is not bound by law to order an independent expert's report before determining the equal value claim. This is a matter for the discretion of the tribunal.
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