Where the terms of a collective agreement are incorporated into employees' contracts of employment, they may be varied from time to time by agreement between the trade unions and the employers, so that the individual contracts are also varied. But, says the Court of Appeal in Robertson and Jackson v British Gas Corporation, if the collective agreement is terminated by the unilateral withdrawal or its terms varied by unilateral action to which the other side does not agree, the individual contracts remain unaffected.
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