500:
of itself mean that it also fulfilled the characteristics of forced labour within the meaning of article 4.2. The logic of the contrary argument would produce strange results. If, for example, a public sector employee were wrongly directed to do something which was in fact beyond the terms of his contract of employment, and the employee did as he was told from fear of disciplinary action, we do not accept that the invalidity of the order would of itself trigger a violation of article 4. Equally, if the 2011 Regulations had unjustifiably discriminated between jobseekers on the ground of gender, and hence had been unlawful, it cannot be right that anyone required to work pursuant to such regulations would therefore have had their article 4 rights infringed. Whether the requirement was invalid under domestic law and whether it involved a violation of article 4 are different issues, and proof of the former does not of itself determine the latter.
488:, on which Ms Lieven relies, was a different type of case. The applicant was a trainee advocate. He was required to represent at his own expense some criminal defendants who were entitled to legal aid. The sanction if he refused to do so was that he would not be registered as an advocate. He complained of a violation of article 4. The obvious difference between that case and the present is that it was not a simple case of a conditional benefit, where the purpose of the benefit was intended to be enhanced by the condition. Rather, it was a case of the state fulfilling its legal obligations to third parties at the expense of the applicant. The court accepted, at para 32, that the menace of the penalty and the lack of voluntariness on the part of the applicant met the starting point for considering whether he had been subjected to forced labour in violation of article 4.
482:(Application No 15906/08) (unreported) 4 May 2010 the applicant was a philosopher by profession. She claimed unemployment benefit and was told that her benefits would be reduced unless she was willing to take up a wider range of employment than she considered suitable. She complained under article 4 that she was being forced to take up labour irrespective of whether it would be suitable for her. The court held that her application was inadmissible. It noted that the obligation of which she complained was in effect a condition for the granting of benefits, and it stated as a general principle that a state which has introduced a system of social security is fully entitled to lay down conditions which have to be met for a person to be eligible for benefits under that system.
467:(1976) 7 DR 161, the applicant was a specialised worker in the building industry. He claimed unemployment benefit and was required as a condition of payment to accept work which he considered to be unsuitable for a person with his qualifications and socially demeaning. He refused the offer and brought a complaint of a violation of article 4. The Commission declared the complaint inadmissible, observing that it was open to the claimant to refuse the work and that its acceptance was only a condition for the grant of unemployment benefit. There could therefore be no question of forced or compulsory labour within the meaning of article 4.
492:
harassing". As we read the judgment, the court was not there setting out five different categories but was using a variety of expressions to elucidate a single underlying concept, which we have referred to as exploitation. In Van Der
Mussele, at para 40, the court concluded for a combination of reasons that there had been no forced labour within the meaning of article 4.2, having regard to the social standards generally obtaining in Belgium and in other democratic societies. The court therefore considered it unnecessary to decide whether the work in question was in any event justified under article 4.3 (d).
31:
403:... it appears clear to us that regulation 2 does not satisfy the requirements of section 17A(1). The courts have no more important function than to ensure that the executive complies with the requirements of Parliament as expressed in a statute. Further, particularly where the statute concerned envisages regulations which will have a significant impact on the lives and livelihoods of many people, the importance of legal certainty and the impermissibility of sub-delegation are of crucial importance. The observations of
460:
of a conditional benefit of that kind comes nowhere close to the type of exploitative conduct at which article 4 is aimed. Nor is it to the point that according to Ms Reilly the work which she did for
Poundland was unlikely in fact to advance her employment prospects. Whether the imposition of a work requirement as a condition of a benefit amounts to exacting forced labour within the meaning of article 4 cannot depend on the degree of likelihood of the condition achieving its purpose.
388:
allowance he had to take part in a new programme that was under trial in his area. He was given a letter stating that if he did not find a job within three months he would be referred to the CAP which would "involve up to six months of near full-time work experience with additional weekly job search support requirements". The letter informed him that a refusal to participate could result in the loss of his benefit, and that, if he had any questions, he should ask his personal adviser.
384:
participation in the scheme was mandatory. That was wrong: it is not mandatory to take part in the sbwa scheme, although once a claimant accepts a place, she must complete the scheme. She asserts that had she been correctly informed about the scheme, she would have exercised her right not to participate in it. Contrary to regulation 4 of the 2011 Regulations ("regulation 4"), Miss Reilly did not receive any written notice concerning her participation in the sbwa scheme.
499:
Does it make a difference to this analysis that what Ms Reilly was told about her obligation to take part in the sbwa scheme, as a condition of receiving jobseeker's allowance, was unauthorised and wrong as a matter of domestic law? The answer is no. The fact that the requirement was invalid does not
455:
at para 32, article 4 was largely based on
Convention 29 of the International Labour Organisation, the main aim of which was to stop exploitation of labour in the colonies. Forced labour is not fully defined and may take various forms, but exploitation is at its heart. Article 4.3 contains particular
415:
Given the conclusion that the 2011 Regulations are ultra vires because they fail to provide a "prescribed description" of any scheme, it is strictly unnecessary to consider the further grounds raised by Miss Reilly and Mr Wilson for contending that the 2011 Regulations were invalid, but we will do so
395:
As a result of his refusal to participate in the CAP scheme, a two-week benefits sanction was imposed on Mr Wilson in early May 2012. Later the same month, it was decided to impose two further benefits sanctions as a result of Mr Wilson's successive failures to attend a job search session with Ingeus
495:
We do not consider that the imposition of the work condition in this case, intended as it was to support the purpose for which the conditional benefit was provided, met the starting point for a possible contravention of article 4. If it did, we do not consider that it fell within article 4.2, having
459:
In the present case we are concerned with a condition imposed for the payment of a claim for a state benefit. Jobseeker's allowance, as its name suggests, is a benefit designed for a person seeking work, and the purpose of the condition is directly linked to the purpose of the benefit. The provision
439:
Insofar as such information is of a general kind, there can be no doubt that it is in everyone's interest that the
Jobcentre adviser provides it to a claimant either in written form or via the website, with an explanation (preferably in writing) as to where and how it can be accessed. If that is not
426:
In our opinion, there was a failure to comply with regulation 4(2)(c). The letter of 16 November 2011 merely informed Mr Wilson that he had to perform "any activities" requested of him by Ingeus, without giving him any idea of the likely nature of the tasks, the hours of work, or the place or places
387:
Mr Wilson was born in 1971, and worked as a qualified Heavy Goods
Vehicle driver from 1994 to 2008, since when he has been unemployed. Mr Wilson started receiving jobseeker's allowance in 2009. In August 2011 his Jobcentre adviser told him that in order for him to continue to receive his jobseeker's
366:
The
Community Action Programme ("CAP") was launched in November 2011, and its stated aim is to help very long-term unemployed claimants back into work. It provides up to six months' work experience, and is administered by private companies, one of which is called Ingeus Ltd ("Ingeus"), most of whose
351:
In March 2012, jobseeker's allowance was being received by just over 1.6 million people aged over 18, of whom around 357,000 had been in receipt of the allowance for more than a year. About 480,000 were aged under 24, of whom 55,000 had been in receipt of the allowance for more than a year. Forecast
318:
On 12 February 2013, the decision of the High Court was overturned on appeal, with the Court of Appeal ruling that the work placement system was unlawful because
Parliament had not given the DWP lawful authority to impose such schemes and because the people involved were not provided with sufficient
288:
Reilly and Wilson claimed the
Regulations should be quashed because (1) they were ultra vires JSA 1995 s. 17A because they failed to prescribe a description of the scheme; (2) there was a failure to comply with the notice provisions in reg. 4; and (3) enforcing the Regulations was unlawful without a
275:
where regulation 2 said schemes were to assist claimants to get employment, but did not contain any description of the scheme. Under regulation 4(2)(c)(e) claimants were supposed to be given written notice of what they were "required to do" and information about the consequences of failing to do so.
474:
ECHR 207 the applicant was a scientist. He claimed unemployment benefit and was required as a condition to accept work which he considered unsuitable. Because of his refusal to do it, his benefit payments were reduced. He complained that by having his benefits reduced he was being forced to do work
399:
Whether one takes the
Employment, Skills and Enterprise Scheme (which is really a group of schemes including the sbwa scheme and the CAP) as a single scheme, or whether, as seems more natural, one takes the sbwa scheme and the CAP as separate schemes, they were undoubtedly schemes which fell within
306:
On 6 August 2012, the High Court ruled (contrary to the arguments of Reilly and Wilson) that the scheme could not be considered slavery, and was not therefore a breach of
Article 4 of the European Convention on Human Rights. On the other hand, it also ruled that the Department for Work and Pensions
362:
The sector-based work academy scheme ("sbwa scheme") was launched in August 2011, and is administered by advisers at social security offices, or Jobcentres, which, until 2011, were run by an executive government agency under the name of Jobcentre Plus. The stated target of the sbwa scheme is those
430:
Properly informed claimants, with knowledge not merely of the schemes available, but also of the criteria for being placed on such schemes, should be able to explain what would, in their view, be the most reasonable and appropriate scheme for them, in a way which would be unlikely to be possible
379:
Miss Reilly was born in 1989 and first claimed jobseeker's allowance in August 2010. Three months later, she got a paid work experience placement at a museum pursuant to a Government scheme, and was paid the minimum wage subsidised by that scheme. When that placement ended, she continued to work
355:
In a nutshell, the amendments to the 1995 Act effected in 2009, including section 17A, envisaged that regulations would (i) require participants to undertake unpaid work, or work-related activity, during a prescribed period, to improve their prospects of employment and (ii) impose sanctions (in
284:
In a joined case, Mr Wilson was given written notice requiring his participation in a scheme for the long-term employed and that his income "may be stopped for up to 26 weeks" if he did not take part. The Jobcentre refused to give any more information. He refused to take part and his income was
422:
In relation to Mr Wilson, there is a dispute which falls to be determined, namely whether the letter of 16 November 2011, quoted in para 24 above, complied with regulation 4(2)(c) and regulation 4(2)(e). In agreement with Foskett J, the Court of Appeal held that it did not satisfy the latter
411:
1 KB 349, 362 are in point: "John Citizen" should not be "in complete ignorance of what rights over him and his property have been secretly conferred by the minister", as otherwise "or practical purposes, the rule of law ... breaks down because the aggrieved subject's legal remedy is gravely
491:
However, that was only the beginning of the inquiry. To amount to a violation of article 4, the work had to be not only compulsory and involuntary, but the obligation to work, or its performance, must be "unjust", "oppressive", "an avoidable hardship", "needlessly distressing" or "somewhat
383:
From 31 October 2011, Miss Reilly participated, albeit unwillingly, in the sbwa scheme. This involved a week's training, a two-week unpaid work placement at a Poundland store, and a further week's training. She participated in the scheme because her Jobcentre adviser informed her that her
270:
s. 17A, the Secretary of State could write regulations for claimants to get JSA in prescribed circumstances, and to be require to take part in schemes of a "prescribed description", which under section 35 meant "determined in accordance with regulations". The Secretary of State wrote the
380:
voluntarily at the museum, with a view to pursuing a career in museums. She has always complied with the jobseeking conditions, and has been committed to seeking employment. Miss Reilly is no longer claiming jobseeker's allowance as she has obtained paid employment at a supermarket.
334:
The Supreme Court held there had been no contravention of Article 4 of the European Convention on Human Rights, but since the court ruled against workfare the comments regarding the human rights do not form part of the reasons for the judgment and therefore are not legally binding.
443:
Ms Lieven's argument involves two steps. First, Ms Reilly's work at Poundland was "exacted ... under menace of penalty", ie disallowance of jobseeker's allowance, and was therefore prima facie forced labour, and for that she relies on the decision of the Strasbourg court in
448:(1983) 6 EHRR 163, para 34. Secondly, the Secretary of State could not rely on article 4.3(d) because the illegality of the regulations and the notice prevented the Secretary of State being able to argue that the work was part of Ms Reilly's "normal civic obligations".
391:
At a meeting in September 2011, Mr Wilson's adviser gave him another letter stating that if he had not found a job in two months, the CAP would commence. Again, it informed him that he might "lose his benefit" if he did not participate in the CAP. ...
574:, summarising the court's findings, emphasised that although the Act was incompatible with the European Convention on Human Rights, "it is up to the Government, subject to any further appeal, to decide what action to take in response".
530:
The findings of the court have been judged to indicate a shift in the nature of "the relationship between social rights and obligations in the context of unemployment policy" in the UK: the founder of the modern UK welfare state,
431:
without such information. Some claimants may have access to information downloadable from a government website, if they knew what to look for, but many will not. For many of those dependent on benefits, voluntary agencies such as
554:
In response to the law change, the law firm acting for Reilly and Wilson, Public Interest Lawyers, lodged submissions to the Supreme Court, arguing that "the actions of the secretary of state ... represent a clear violation of
280:
advisers to give claimants "full details" of available schemes. Reilly received no written notification requiring her to join a scheme, but was simply told by a Jobcentre adviser that training and Poundland was mandatory.
320:
272:
435:
play an important role in informing and assisting them in relation to benefits to which they may be entitled, how they should apply, and what matters they should draw to the attention of their Jobcentre adviser.
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done, it may be harder evidentially for the Secretary of State to show that a claimant has been given all the information fairly required in order to be enable him or her to make an informed decision.
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who do not have any serious barriers to finding work, but who would benefit from a short period of work-focused training and work-experience placement linked to a genuine job vacancy.
551:
to retrospectively make its unlawful sanctions against benefits claimants legal, in order to avoid potentially having to repay unlawfully withheld benefits payments of around £130m.
244:
policy of making the unemployed work for private companies to get unemployment income. The outcome of the case affects over 3,000 claimants and entails around £130m unpaid benefits.
687:
783:
976:
570:" under Article Six of the Convention on Human Rights. The government appealed this ruling, but on 29 April 2016, the Court of Appeal upheld the previous court's decision;
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particular, loss of the allowance) on those who without good cause failed to participate in such schemes. Those regulations materialised as the 2011 Regulations ...
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1070:
1005:
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456:
instances of obligatory labour which are common features of life in democratic societies and do not represent the mischief at which the article is aimed.
535:, conceived the classical welfare state as freeing people from Want, while obliging them to work when possible. Kenneth Veitch has argued the rulings in
662:
1320:
883:
396:
on two occasions during April 2012. In total, these second and third benefits sanctions resulted in a cessation of benefit payments for 6 months.
289:
published policy on the nature of the scheme and unpaid work. Reilly added that (4) needing to take unpaid work was forced labour contrary to the
1330:
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138:
539:
imply that Want is now used as a threat to ensure that welfare claimants habituate themselves to the demands of the contemporary workplace.
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1063:
506:
694:
1305:
419:
As described in para 21 above, no written notice was given to Miss Reilly, contrary to regulation 4(1) and 4(2) set out in para 12 above.
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of work. It seems to us, therefore, that the letter failed to give Mr Wilson "details of what required to do by way of participation".
359:
A variety of "work for your benefit" programmes have been made under the 2011 Regulations. The present appeals concern two such schemes.
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to which he had a conscientious objection, contrary to article 4. The application was declared manifestly ill-founded and inadmissible.
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1315:
598:
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1310:
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240:" policy was unlawful. Caitlin Reilly, an unemployed geology graduate, and Jamieson Wilson, an unemployed driver, challenged the
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The government appealed the judgment, but on 30 October 2013, the decision of the Appeal Court was upheld by the Supreme Court.
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had breached its Regulation 4 (which required certain details of the Work Programme to be given to participants in writing).
323:. The court did not state whether or not the current case impinges on Article 4 of the European Convention on Human Rights.
943:
41:
1013:
593:
404:
225:
759:"The Queen (on the application of) Caitlin Reilly and Jamieson Wilson -v- Secretary of State for Work and Pensions"
734:"The Queen (on the application of) Caitlin Reilly and Jamieson Wilson -v- Secretary of State for Work and Pensions"
566:, sitting at the High Court in London, ruled that the retrospective nature of the legislation interfered with the "
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On 19 March 2013, before the appeal to the Supreme Court was completed, the Government also passed the
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R (on the application of Reilly (No. 2) and Hewstone) v The Secretary of State for Work and Pensions
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8:
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R (on the application of Reilly and another) v Secretary of State for Work and Pensions
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A Paz-Fuchs and A Eleveld, 'Workfare Revisited' (2016) 45(1) Industrial Law Journal 29
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and the rule of law, as an interference in the judicial process by the legislature".
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by forcing her to attend two weeks of 'training' and work for another two weeks at
221:
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1048:
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Kenneth Veitch, 'Unemployment and the Obligatory Dimension of Social Rights', in
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Jobseeker's Allowance (Employment, Skills and Enterprise Scheme) Regulations 2011
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Jobseeker's Allowance (Employment, Skills and Enterprise Scheme) Regulations 2011
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regard to the Strasbourg guidance and the underlying objective of the article.
1299:
1214:
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1006:"Government loses latest round of legal battle over its back-to-work schemes"
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932:, ed. by Toomas Kotkas, Kenneth Veitch (Abingdon: Rutledge, 2017), pp. 58-76.
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In our judgment the argument fails at the first step. As the court noted in
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without pay, just in order to receive Jobseeker's Allowance. Under the new
1229:
List of British organisations who have participated in workfare programmes
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provision, but they also found that it did not satisfy regulation 4(2)(c).
1199:
258:
198:
856:"Graduate's Poundland victory leaves government work schemes in tatters"
1184:
352:
expenditure on the allowance in the year 2011/12 was just under £5bn.
277:
263:
241:
663:"Poundland 'forced labour' was lawful work scheme, High Court rules"
588:
634:
632:
218:
R (Reilly and Wilson) v Secretary of State for Work and Pensions
1204:
1169:
930:
Social Rights in the Welfare State: Origins and Transformations
629:
1209:
944:"Labour abstention on workfare bill prompts party infighting"
1272:
Department for Work and Pensions v Information Commissioner
310:
Both parties expressed their wish to appeal the judgement.
276:
After, the SS announced sub-schemes and issued guidance to
1164:
1144:
319:
information about it. The Court of Appeal quashed the
1265:
R (Reilly) v Secretary of State for Work and Pensions
24:
R (Reilly) v Secretary of State for Work and Pensions
557:
Article 6 of the European Convention on Human Rights
1078:
367:recruits are referred or identified by Jobcentres.
1297:
373:The facts relating to Miss Reilly and Mr Wilson
1064:
291:European Convention on Human Rights article 4
1119:Day One Support for Young People Trailblazer
1287:Jobseekers (Back to Work Schemes) Act 2013
1071:
1057:
830:"Reilly and Wilson -v- Secretary of State"
604:Jobseekers (Back to Work Schemes) Act 2013
549:Jobseekers (Back to Work Schemes) Act 2013
29:
1321:Supreme Court of the United Kingdom cases
942:Muir, Hugh; Malik, Shiv (21 March 2013).
941:
599:Youth unemployment in the United Kingdom
542:
878:
876:
1331:United Kingdom constitutional case law
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914:: CS1 maint: archived copy as title (
814:: CS1 maint: archived copy as title (
718:: CS1 maint: archived copy as title (
184:Lord Mance, Lord Sumption, Lord Clarke
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117:[2012] EWHC 2292 (Admin)
1012:. Press Association. Archived from
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232:case that found the conduct of the
42:Supreme Court of the United Kingdom
13:
1306:Unemployment in the United Kingdom
640:"Court challenges UK work schemes"
594:Unemployment in the United Kingdom
313:
14:
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226:United Kingdom constitutional law
854:Malik, Shiv (12 February 2013).
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234:Department for Work and Pensions
1316:2013 in United Kingdom case law
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584:Work Programme (United Kingdom)
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1326:United Kingdom labour case law
1311:Workfare in the United Kingdom
1080:Workfare in the United Kingdom
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480:Schuitemaker v The Netherlands
409:Blackpool Corporation v Locker
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1138:Workfare Providers ('Primes')
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176:Lord Neuberger, Lord Toulson
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1160:Employment and Skills Group
1104:Sector Based Work Academies
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537:Reilly v Secretary of State
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252:Ms Reilly claimed that the
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1094:Community Action Programme
626:(Hart 2019) ch. 16, p. 723
400:the ambit of regulation 2.
111:[2013] EWCA Civ 66
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1129:Community work placements
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446:Van Der Mussele v Belgium
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624:A Casebook on Labour Law
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472:Talmon v The Netherlands
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1099:Mandatory Work Activity
562:On Friday 4 July 2014,
433:Citizens Advice Bureaux
1045:(Hart 2019) ch 16, 723
572:Lord Justice Underhill
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285:stopped for 6 months.
1248:Solidarity Federation
568:right to a fair trial
543:Subsequent litigation
347:
345:wrote the following:
1087:Workfare Programmes
796:on 28 February 2013
465:X v The Netherlands
268:Jobseekers Act 1995
1224:Workfare Companies
1190:Prospects Services
254:Secretary of State
204:administrative law
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1180:Newcastle College
896:on 11 August 2014
533:William Beveridge
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113:(Court of Appeal)
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1243:Boycott Workfare
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1016:on 30 April 2016
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61:30 October 2013
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865:12 February
800:18 February
704:18 February
507:Lord Clarke
412:impaired".
259:ultra vires
199:ultra vires
181:Concurrence
173:Decision by
149:Lord Clarke
1300:Categories
1257:Litigation
1236:Opposition
1185:PeoplePlus
1033:References
511:Lord Mance
302:High Court
256:had acted
230:labour law
144:Lord Mance
89:Transcript
78:3 WLR 1276
75:WLR(D) 413
990:21 August
961:21 August
956:0261-3077
839:21 August
768:21 August
743:21 August
646:21 August
526:Reactions
416:briefly.
278:Jobcentre
264:Poundland
242:Jobcentre
66:Citations
1020:30 April
910:cite web
900:7 August
810:cite web
714:cite web
589:Workfare
578:See also
517:agreed.
405:Scott LJ
297:Judgment
238:workfare
189:Keywords
1175:Maximus
222:UKSC 68
81:AC 453]
58:Decided
1205:Seetec
1170:Ingeus
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93:BAILII
72:UKSC 6
1210:Serco
1200:Rehab
894:(PDF)
887:(PDF)
794:(PDF)
787:(PDF)
698:(PDF)
691:(PDF)
672:2 May
610:Notes
248:Facts
224:is a
38:Court
1195:Reed
1150:BEST
1022:2016
992:2019
963:2019
952:ISSN
916:link
902:2014
867:2013
841:2019
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770:2019
745:2019
720:link
706:2013
674:2013
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513:and
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