In Usdaw v Ethel Austin Ltd (in administration); Usdaw and another v Unite the Union and others  IRLR 686 EAT, the EAT held that s.188 of the Trade Union and Labour Relations (Consolidation) Act 1992 must be read so that the requirement for collective redundancy consultation is not limited to individual establishments where it is proposed to make 20 or more redundancies within 90 days.
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