Where employers pay for an employee's training, they can require a reasonable minimum period of service after the training is completed. In Strathclyde Regional Council v Neil, the Sheriff Court holds that a contractual provision for repayment by the employee of the costs incurred is not a penalty and can be enforced, provided the amount relates to the loss suffered by the employer.
Where an employer has mistakenly overpaid an employee, the money can be recovered if it was paid because of a mistake of fact. However in a warning to employers operating computerised payment systems, the Court of Appeal in The County Council of Avon v Howlett holds that the defence of estoppel may operate to prevent recovery of all the money even if the employee has spent only some of it.
In Milsom v Leicestershire County Council [1978] IRLR 433 IT, the Industrial Tribunal held that a pay statement must detail the amount of each variable deduction and the purpose for which it is made, and not merely label an item "miscellaneous deduction".