Notes re: seminar given to the Law Society of Jersey on 25 May 2016 about the development of the employment/labor laws of Jersey, Channel Islands
Speaker: Advocate Vicky Milner, Callington Chambers, St Helier, Jersey, Channel Islands
(1) Laws are constantly changing
It is a truism that laws are constantly changing.
In Selby v. Romeril (contract law case) 1996 the Royal Court (Sir Philip Bailhache, Bailiff) said about Pothier and Jersey contract law:-
“…Pothier has often been treated by this court as the surest guide to the Jersey law of contract. It is also true, however, that Pothier was writing two centuries ago and that our law cannot be regarded as set in the aspic of the 18th century.”
This statement about the ongoing development of our law is as true of our employment law as any other area – and lately perhaps this is particularly true of our employment law. We have seen significant changes in recent years and these changes are continuing.
(2) Why are employment law developments of interest?
Employment law developments may be considered of interest for reasons including the following:
- a. Employment and the individual:
For many adults, employment is fundamental to who we are and how we define ourselves.
People returning from a long absence from the work place, such as a mother returning from maternity leave or someone who has been out of the workplace on long term sick leave, may face considerable psychological challenges in fitting back in.
The ability to go to work each day and do a job which is of value can be enormously validating and important to our sense of worth – a point which is of course as true of people with disabilities as anyone else.
Aspire, a Jersey charity which supports people with learning disabilities, has a guide which includes the following wording:
“…we believe that work develops our sense of self and self-esteem. It can provide us with life-long learning opportunities and allows us to engage with members of the community.
Working within and with the wider community will teach our workers new skills, while also enabling the public to mix with and learn from people with different learning abilities.”
- b. Employment and the economy:
Employment and unemployment are of direct relevance when considering the health, maturity and developmental changes of any economy. Looking at developments in employment law gives us a window into the history and developments of an economy. We can see this both in:
- Case law - eg cases such as Rossborough v Boon & Aziz (see below), which are about business and competition; and
- Legislation - eg the Control of Housing & Work (Jersey) Law 2012 and age discrimination law, both of which are concerned with matters including managing and balancing the needs of the population given available resources.
(3) Jersey context: Jersey’s legal heritage and the influence of the laws of other jurisdictions
Jersey employment law is just one subset of Jersey’s body of laws. Jersey is not simply an adjunct of the United Kingdom. Our jurisprudence – our body of laws of this island, as an independent jurisdiction - goes back to time immemorial.
To give some examples:
- Laws relating to dried and salted fish were referred to in the Quo Warranto Rolls of 1299 and 1309:
“the Seigneurs continued to claim esperqueries on their maritime fiefs…which they claimed to have enjoyed from time immemorial”
(“Esperqueries” = sites where conger [eel] might be dried and salted.)
- Our Public Registry is one of the oldest land registries in Europe having been created in 1602 at the instigation, of Sir Walter Ralegh, then Governor of Jersey.
This is important: here in Jersey we should never assume that our law is the same as the law elsewhere.
Of course it is true that:
- Some of our laws are derived from the law of Normandy.
- Some of our law may be shared with Guernsey.
- Increasingly, much of our law looks to the law of England and Wales and also to the EU (eg data protection legislation).
However the words of Sir Philip Bailhache, then Bailiff, in the Royal Court’s 2005 judgment in Grove & Briscoe v Baker are arguably of relevance to our legal system generally:
“…determining the Jersey law of contract is too often presented by counsel…as a battle between legions carrying the flags of French law and English law respectively. The court is too often enjoined to apply French law to this problem, or to apply English law to that. This court is concerned only to apply the law of Jersey.”
“If we can do so, we will apply the custom and the law laid down in previous decisions of this court. If the law cannot be found in that way, [then, and only then] we must adopt principles from elsewhere.”
(4) Two key employment cases (the customary law picture)
The following two cases are really important for the following reasons:
- They provide a 21st century look at employment law in Jersey immediately before the Employment (Jersey) Law 2003 came into force in July 2005;
- They show us the contractual and customary law framework for our employment law that continues to be of direct relevance today.
They are both judgments of Sir Michael Birt, then Deputy Bailiff.
a. Rossborough v Boon & Aziz (2001)
Boon & Aziz were two senior insurers employed by Rossborough. Their contracts included two year non-solicitation and non-dealing restrictive covenants. Rossborough decided to change the group pension scheme from a final salary scheme to a defined contribution or ‘money purchase’ pension scheme. (This is a change that was happening across the private and public sector – and of course now there are very few employers that continue to have final salary pension schemes, which are more expensive and higher risk for businesses than money purchase (defined contribution) schemes.)
During consultation about the change, Boon & Aziz both objected to the change. When it was confirmed that it would be implemented regardless they both resigned, claiming that this was a fundamental change in their terms of employment and that they had been constructively dismissed.
Subsequently they both joined another insurance company and they alleged that their non-solicitation and non-dealing restrictive covenants did not apply, because of the constructive dismissal.
Rossborough obtained ex parte injunctions, prohibiting Boon & Aziz from soliciting or dealing with Rossborough clients for the balance of the two year period.
The judgment looks at the principles relating to restrictive covenants, including Jersey cases from the 1960s: Nicol –v- Egan (1968) in which the Court upheld a 10 year non-competition clause preventing an employee from working as a physiotherapist in Jersey; and Wallis –v- Taylor in which the Court upheld a one year clause preventing the employee from working as a driving instructor in Jersey.
Referring back to Wallis –v- Taylor (1965) the Royal Court noted that:-
“It is an established principle of Jersey Law that ‘la convention fait la loi des parties’ …
Where an agreement is freely entered into between responsible persons, good cause must be shown why it should not be enforced…”
The ex parte injunctions were upheld at the inter partes hearing.
This case clarifies principles which continue to apply in Jersey in relation to:
- Applications for injunctive relief
- Restrictive covenants
- Constructive dismissal
b. McDonald v Parish of St Helier (2005)
This case was heard on 3 June 2005, shortly before the Employment (Jersey) Law 2003 came into force on 1 July 2005.
McDonald was a driver/labourer for Parish of St Helier and his employment contract included a disciplinary process to be followed in misconduct cases. McDonald was dismissed without notice for taking unauthorised leave.
The Royal Court’s judgment records the following:
“The plaintiff then appealed to the Disputes Committee. On 7th June the Disputes Committee upheld his appeal. Whilst noting that the Parish was justifiably disappointed at the abuse of its trust…it considered the decision was too harsh… The Disputes Committee decided that the plaintiff should instead be issued with a final written warning, be required to repay the wages he had received during his unauthorised absences and be suspended without pay for one week.
[However, instead] on 16th June 1999 the Constable wrote to the plaintiff to the effect that the Parish was dismissing him with eight weeks’ payment in lieu of notice. It is agreed that this was the required period of notice under the contract and that the plaintiff has received the relevant sum…
In broad outline the plaintiff alleges that, by dismissing him in June 1999, the Parish has breached three implied terms of the contract as follows:-
(i) that disciplinary matters should be dealt with solely in accordance with the provisions set out in the conditions i.e. it was bound by the decision of the Disputes Committee;
(ii) that the Parish would not, without reasonable and proper cause, conduct itself in a manner which was likely to destroy and/or damage the relationship of trust and confidence between employer and employee;
(iii) that the Parish would not terminate the plaintiff’s employment without good reason and would only do so in good faith i.e. would not unfairly dismiss the plaintiff.
12. …by the time the matter came to trial, there was no issue on liability. The Parish admitted having breached the contract of employment. The issue which remained was as to the quantum of damages which should be awarded for such breach. Both sides accepted that the longstanding position under English common law is that damages in such cases are limited to the wages for the required period of notice to terminate the contract. As the plaintiff has received eight weeks’ wages in lieu of notice, the Parish argues that he is entitled to nothing more. The plaintiff, on the other hand, argues that the Court should develop the common law so as to permit the plaintiff to recover his real losses, namely the continuing loss of income until he reaches 65 and the loss of his pension rights.
13. Both parties agree that there is no previous judicial decision in Jersey which deals with the point; nor do either of them suggest that is any principle of Norman or French law which is of assistance. On the contrary, both are agreed (correctly) that in matters relating to damages for breach of contract, the Court has traditionally looked to English law for guidance.
40. The customary law does not stand still and we agree that, in the absence of legislation, it would in theory be open to the law of Jersey to develop along the lines suggested by Mr Le Quesne. But we see no answer to the arguments of the majority in Johnson. As Lord Millett put it at para 80 (commenting on the effect of introducing a common law remedy for unfair dismissal in the face of the statute):-
“In other cases, where the common law would be giving a remedy in excess of the statutory limits or to excluded categories of employees, it would be inconsistent with the declared policy of Parliament… And, even more importantly, the co-existence of two systems, overlapping but varying in matters of detail and heard by different tribunals, would be a recipe for chaos. All coherence in our employment laws would be lost.”
Lord Nicholls summarised the arguments very persuasively at paras 11-14 of Eastwood and ended by saying at para 14:-
“But Parliament has occupied the field relating to unfair dismissal. It is not for the courts now to expand a common law principle into the same field and produce an inconsistent outcome.”
41. Does it make any difference that the Jersey legislation is not yet in force so that, for example, we do not know exactly what limits there may be upon the compensation available pursuant to the statutory remedy? We do not think so. To use Lord Nicholls’ expression, the States have occupied the field. They have passed legislation in the knowledge of what the established customary law provides. As with the English legislation, the States have chosen not to provide simply for a statutory implied term against unfair dismissal, leaving the courts to award damages on the usual contractual basis. They have, as in England, decided to remove jurisdiction in such cases to a specialist tribunal, to provide very short time limits, to provide a mechanism for limiting the amount of compensation and to provide that certain employees should be excluded from any remedy. If the Court were to develop the customary law as Mr Le Quesne suggests, there would, immediately upon the coming into force of the legislation, be the inconsistency and recipe for chaos envisaged in Johnson. Indeed, were we to find for the plaintiff and were the Parish to appeal, it seems probable that the Court of Appeal would have to deal with a position where the statute was in force and it was having to decide whether to develop the customary law in a manner inconsistent with that legislation…
43. We do not think that this would be an appropriate way in which to proceed. The fact is that, although the statute may not yet actually be in force, the legislature has made a decision as to how it wishes to proceed. The legislation has been passed and is ready to be implemented. In our judgment it would not be proper for the Court, in these circumstances, to develop the customary law in a manner which it knows is quite inconsistent with the path chosen by the legislature. It would be a recipe for chaos for the Court to proceed as Mr Le Quesne suggests…
49. For these reasons we dismiss the plaintiff’s claim.”
These two cases remain relevant when dealing with Royal Court employment law cases. If for example, we are considering restrictive covenants, unpaid bonuses or breach of the duty of trust and confidence by the employer, it is still to these cases that we look.
(5) Development of the new employment law framework
While there were a number of Jersey employment law cases in the 1960s, from 1970-2000 there were very few published judgments on employment-related matters – 1 or 2 a year. The cost of litigating through the Royal Court was of course substantial, making Royal Court employment litigation a rare bird. (The Petty Debts Court may have been used for lower value cases but these judgments are not reported.)
Why was there no push for employment protection?
Historically, certainly from the 1970s until recently times, Jersey had almost full employment. The financial services industry made Jersey one of the highest earning jurisdictions in the world. (According to The Guardian, in 2007 Jersey was: “the third-richest country in the world measured by GDP per capita, beaten only by Luxembourg and Bermuda”.) Like anywhere else, Jersey has always had poverty and inequality, but they may have been masked by the disproportionate percentage of wealthy islanders. In the latter part of the 20th century, the Island’s problems may have started to become more apparent, perhaps with the decline in the tourism and agriculture sectors from the 1980s onwards. But unemployment was still comparatively very low. This may well have been relevant to the late introduction of meaningful employment legislation. If you will lose little or no money if you lose your job – if you can get another well-paid job the next day - protection from unfair dismissal is not necessarily a burning issue.
Nonetheless, the inequality gap was increasingly recognised during the 1990s. This recognition led to the “Fair Play in the Workplace” review and consultation in the late 1990s. Information about this can be found in Melanie Cavey’s 1999 Jersey Law Review article, which includes the following:
"In December 1998 a consultation document entitled "Fair Play in the Workplace - Good employment practice in Jersey" ("the consultation document") was widely circulated… In his foreword to the consultation document the [then] President of the ESSC, Deputy Terry Le Sueur, stated that:-
"…Jersey cannot justify remaining one of the few states that denies its citizens such basic rights as protection from unfair dismissal and freedom from discrimination. At the same time we should not become as heavily regulated as some other states within Europe and elsewhere. A sensible balance needs to be struck.
The purpose of the consultation process, therefore is to reach consensus in our society on a legal framework which will provide standards of decency and fairness in the workplace but not undermine the social and economic benefit that we have from a healthy economy and full employment."”
A new framework needed to be set up, which would review present law, introduce new protection and have an appropriate enforcement structure. (One of the historical problems had been that, while there were some employment laws, it was not easy for employees, particularly low earners, who may have been the most vulnerable, to enforce their rights. Accordingly a whole new regime was required.)
Following consultation and debate over the next four years, the Employment (Jersey) Law 200- (the “Employment Law”) was passed in 2003 and was brought into force on 1 July 2005.
This revised and consolidated existing legislation relating to terms of employment and notice periods, and introduced additional rights including:
- Minimum wage
- Entitlement to rest days and holidays (annual leave)
- Protection from unfair dismissal
In relation to protection from unfair dismissal, at the time the Employment Law was introduced there were various qualifying criteria. A number of criteria have subsequently been changed or will be changed in the context of the implementation of discrimination legislation, including that during the employment in question the applicant:
- Worked a minimum of 8 hours per week; and
- At the date of dismissal was below normal retirement age.
(7) Key organisations
As noted above, there were significant enforcement problems under the old system. It was imperative that a new structure be put in place in order to ensure that the new regime “had teeth” – that it was meaningful legislation, which could be enforced by those who were intended to be protected (or those acting on their behalf).
While there have been some changes, the structure can now be summarised as follows:
- Social Security Department: the department of the States of Jersey responsible for employment legislation
- Employment Forum: an independent body, created under the Employment Law, responsible for consultation on employment law matters (including the annual minimum wage review, for example)
- Jersey Advisory & Conciliation Service: JACS is an independent body, created by statute, which describes itself as follows:
“JACS is the employment relations service and is here to help employers, employees and trade unions work together for the prosperity of Jersey business and the benefit of employees”
- Jersey Employment & Discrimination Tribunal (the “Tribunal”): created under the Employment Law, responsible for enforcement of employment law rights in accordance with Article 86 of the Employment Law
- Royal Court: the body within Jersey’s court system with responsibility for:
- Appeals against decisions of the Tribunal, under Article 94 of the Employment Law;
- Those matters under Article 86(3) of the Employment Law which are outside the remit of the Tribunal and also non-statutory contractual claims worth in excess of £10,000 (see Article 104 of the Employment Law and the Employment (Awards) Order 2009)
There are other bodies whose work is also relevant, including the Citizens Advice Bureau (“CAB”) and the Jersey Community Relations Trust (“JCRT”).
(8) Tribunal and Royal Court cases
The new law had an immediate impact. A number of claims were quickly lodged.
Almeida v Pizzeria Romana
The Tribunal heard its first full case in October 2005, just 3 months after the Employment Law came into force. This was the case of Almeida v Pizzeria Romana.
Mr Almeida was a waiter. He provided his employer with a letter requesting “written confirmation of my weekly working hours as I believe that I am not being paid the legal minimum wage in respect of hours worked.” He was promptly sacked. He successfully brought a range of claims under the Employment Law including in respect of the minimum wage, unfair dismissal and notice.
In some ways this case may be considered fairly typical of the matters passing through the Tribunal to date. It demonstrates some of the strengths of the system, which provides a relatively quick, easy and cheap way for an employee who has been seriously wronged to receive:
- compensation; and
- public recognition that a person has been dismissed through no fault of this own.
Numerous cases have followed. In the first year there were 176 applications to the Tribunal. From 2010 to 2014 (inclusive), the average number of cases going to a full Tribunal hearing (as opposed to an interlocutory hearing) was 53 per annum.
It remains the case that the majority of complaints lodged are resolved with the assistance of JACS, which plays a vital function.
Since the Employment Law came into force there have been a number of appeals to the Royal Court, including the following early decisions:
- Voisin v Brown (2007) – the role of the Tribunal in redundancy dismissal cases
- RBSI v Jones (2007) – disclosure in Tribunal procedings
- CI Fire & Security v Browning (2008) – the ability of the Tribunal to issues fines for offences under the Employment Law
Subsequently there have been other Royal Court appeal decisions under the Employment Law, all of which have helped to:
- refine the application of the Employment Law and the operations of the Tribunal; and
- clarify how the Employment Law works within our wider jurisprudence, including when balanced with our human rights legislation for example.
(9) The Great Recession; Woolworths
From the end of the 20th and into the 21st century Jersey had a booming economy. Internationally, the finance industry of the island punched well above its weight.
While the global economy may have started to teeter from 2007, initially there were few concerns in Jersey. Law firm business continued to boom. (Cf the numerous Royal Court and Court of Appeal judgments from 2003-2009 in the Alhamrani case.)
The States of Jersey had consulted on redundancy and TUPE in 2006. While the idea of statutory redundancy pay found broad support, it was not then top of the agenda, when considered alongside other employment law matters. (TUPE was felt by many not to be appropriate for Jersey, albeit the employment law implications of privatisation/States’ outsourcing were raised, and continue to be raised, from time to time. See for example the State of Jersey Complaints Board decision of 24 February 2016 in respect of the complaint brought by Unite against the Minister for Infrastructure.)
On 15 September 2008 Lehman Brothers crashed. According to The Telegraph (report 23 December 2008):
“The day Lehman Brothers filed for bankruptcy was the day the worst economic crisis in living memory began in earnest… At 9am, shares in HBOS, Britain’s biggest mortgage lender, crashed 34 per cent in early trading. By noon, panic had gripped the London Stock Exchange and the FTSE had shed almost 400 points…within three weeks the FTSE would fall below 4,000, wiping billions off the value of our leading companies.”
In December 2008 one of the UK’s most famous and popular stores, Woolworths, collapsed.
Jersey was not immune to these dramatic changes: in January 2009 all of the Woolworths’ employees were made redundant. While staff were expected to receive their final salary payments, there was no prospect of payment of other statutory entitlements such as notice. There was no point in suing the business, which was insolvent.
The States of Jersey promptly agreed to cover Woolworth employees’ pay and notice entitlements. This was an unusual measure which the island would not be able to replicate on an open-ended basis.
(10) Redundancy protection; changes to the Employment Law
In April 2009 Jersey’s temporary insolvency scheme was introduced, which subsequently become the Insolvency Benefit scheme (administered by the Viscount’s Department). This scheme is notable for being a demonstrably needs-based, simple and effective scheme.
Statutory redundancy pay was introduced in 2010, by amending the Employment Law, together with other related measures, including requirements in respect of collective consultation in mass redundancy situations.
Since 2010 there have been numerous further amendments to the Employment Law, including in connection with the implementation of the Discrimination (Jersey) Law 2013.
(11) The introduction of statutory protection from discrimination
Back in October 1996, the Policy and Resources Committee had produced a report into the extent of racism and racial discrimination in Jersey. Projet P.32/2002 noted:
“From the comments and detailed analysis in the October 1996 report, the conclusion drawn was that racist attitudes do exist in Jersey. In fact, in its findings, the report concluded that -
“Although the Island does not have a problem of the magnitude experienced by some other jurisdictions, it is clear from the available evidence that racial discrimination is not entirely absent from Jersey.”
(October 1996 Report, page 7.)”
At the time of the Fair Play review at the end of the 1990s, legislation tackling discrimination was one of the employment protection measures that the States intended to implement.
While some initial delay may have been attributable to slow administrative processes (the Home Affairs Department, which has a broad and complex remit, was originally responsible for the race discrimination legislation), by the time responsibility for discrimination legislation moved to the Social Security Department it was intended that workplace-related protection would be introduced on a rolling/staggered basis. This was largely for the benefit of industry, including the island’s numerous small businesses. See for example the Chief Minister’s response to Q.1240/5(8688):
“The decision to phase in the different areas of the discrimination law allows local employers and service providers to build up experience and confidence in this area, without imposing an undue burden on small companies.”
Following consultation over a number of years, the discrimination law was passed in 2013 and came into force in 1 September 2014. Our legislation is a combination of:
- the overarching or umbrella primary legislation (the Discrimination (Jersey) Law 2013), which at Schedule 1 confirms race as the first “protected characteristic”;
- subsequent regulations covering additional protected characteristics, including the Discrimination (Sex and Related Characteristics) (Jersey) Regulations 2015 which came into force on 1 September 2015.
Not all discrimination is unlawful, only that behaviour, relating to those protected characteristics, which is covered by the legislation.
At present race and sex (covering gender, sexual orientation and gender reassignment) are protected characteristics. Further regulations covering age and disability discrimination are intended to be implemented on 1 September 2016 (age) and in 2017/2018 (disability).
The introduction of each new protected characteristic has implications. For example:
- With race you have to consider the island’s immigration, work and housing laws.
- With sex discrimination, aside from matters relating directly to pregnancy and maternity, issues arise in relation to part time working. This is because at present in Jersey more women work part-time than men. A criterion that discriminates against part-time workers may also be indirectly sex discriminatory, women being disproportionately adversely affected.
It is because of this that the 8 hours threshold for protection from unfair dismissal was removed, under the Employment (Amendment…) (Jersey) Regulations 2015.
Now if you are employed by someone at all, even for 1 hour a week, as long as you meet the other qualifying criteria you are protected from unfair dismissal – giving rise to new problems in respect of zero hours contracts affecting numerous workers within the island.
- With age you have to consider the rules around pensions, retirement and the upper age limit for unfair dismissal.
- In relation to disability see again the Chief Minister’s response to Q.1240/5(8688):
“…the Chief Minister’s Department is already working on a disability strategy for Jersey, which will gather information on the experience of local people living with a disability. From this knowledge, a disability strategy will be developed during 2015/2016.
Once a strategy has been agreed, work can begin on the development of disability regulations, for introduction in 2017/2018. Disability discrimination is the most complex of the areas (characteristics) to be covered and care will need to be taken to find the appropriate balance of regulations to protect individuals without imposing an undue burden on employers and service providers. The characteristic of disability is expected to require the most preparation and the most adjustment across wider society, not just for employers, and so we expect the preparations to take longer than for the other characteristics.
For example, compared to the other characteristics, a different approach will be required because behaviour is less likely to be a result of people’s prejudices about, or hostility towards, disabled people, but is more as a result of workplaces and premises being designed in such a way as to exclude or limit access to some disabled people. Full consultation will be required as to the scope and the extent to which reasonable adjustments should have to be made to accommodate the needs of disabled people.
A careful approach will also be needed in the legal definition of disability to provide the appropriate separation from sickness or illness, but still include an appropriate range of conditions.”
(12) Recent Tribunal decisions
First judgment under the Discrimination (Jersey) Law 2013
23 May 2016 saw the publication of Jersey’s first (and long-awaited) judgment under the Discrimination (Jersey) Law 2013 (the “Discrimination Law”).
The case of Bisson v Condor Limited was brought under the gender reassignment provisions of the Discrimination Law, which provide rights for transgender persons. The judgment is brief and does not offer any great insight into this important new legislation. It is noteworthy, however, that the outcome of the case, in which the Tribunal found in Ms Bisson’s favour, was not an award of damages or compensation but a recommendation under Article 42(1)(c) of the Discrimination Law, ie a recommendation that:
“…the respondent take, within a specified period, action appearing to the Tribunal to be practicable for the purpose of obviating or reducing the adverse effect on the complainant of any act of discrimination to which the complaint relates.”
Zero hours workers
The same day www.jerseylaw.je published a number of other Tribunal judgments. Two deal with zero hours contracts, Carre v Marchem (Europe) Ltd and Vibert v Agency Ltd. While they have received far less publicity than the Bisson case they are no less important, as they deal with a legal conundrum that will impact on many of the island’s workers.
As the Tribunal noted in identical terms in each judgment:
“This is a problematic and controversial area of the law.”
Because of the dates of employment in each of these two cases, the question arising from the lifting of the 8 hours qualifying criterion in unfair dismissal cases has not been resolved.
This remains a “watch-this-space” area of Jersey employment law.
(13) Challenges ahead
Like everywhere in the world, we are living through a period of enormous change, including as a result of:
- climate change
- the increasing global population
- the changing age profile of our population
This creates new challenges and uncertainty. For example:
- With mobile devices many of us can now work almost anytime, anywhere. Is that good or bad? What are the implications of this level of connectivity in relation to rest breaks, holidays, stress levels and personal injury for example?
- How will we manage the explosion of data that arises from this constant connectivity? What about privacy and the workplace? What are the implications of the EU General Data Protection Regulation for Jersey, given that, to an extent, this is extra-territorial?
The unprecedented nature of these changes was identified in Jersey’s 2012 white paper on health care, entitled “Caring for each other, caring for ourselves”, which included the following prediction:
“Between 2010 and 2040 there will be a 95% increase in the number ofpeople over 65”
It is hoped that the States of Jersey will look at ongoing developments in legislation pragmatically, holistically and taking an evidence-based approach to change.