In Dowling v Ilic Haulage and another  All ER (D) 87 (Apr) EAT, the Employment Appeal Tribunal held that the obligations under a continuation order made under the Trade Union and Labour Relations (Consolidation) Act 1992, section 164 do not transfer to the transferee of an undertaking by operation of the Transfer of Undertakings (Protection of Employment) Regulations 1981.
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