“… 1 AC 816 at [19], Lord Nicholls approved the following statement of the principle made by Staughton LJ in Secretary of State for Social Security v Tunnicliffe [1991] 2 All ER 712 at 724:…”
“…nt years has changed. The source of that change is to be found in a decision of Staughton LJ in the case of Secretary of State for Social Security v Tunnicliffe[1991] 2 All ER 712. In a judgment which has frequently been cited since that time, Staughton LJ, at page 724f, identified this principle:…”
“…The House of Lords approved the test set out by Staughton LJ in his judgment in Secretary of State for Social Security v Tunnicliffe [1991] 2 All ER 712, 724, CA and held that it could not have been Parliament’s intention that s.3(1) should alter existing rights and obligations under an agreement which pre-date…”
“…d Nicholls thus sought the underlying rationale and gained assistance from the judgment of Staughton LJ in Secretary of State for Social Security v Tunnicliffe [1991] 2 All ER 712 at 724:…”