Employees working abroad for an English company can claim statutory holiday pay in the English tribunals as long as English law is the governing law of the employment contract (or provides the "mandatory rules" applicable to the employment, because England is the country most closely connected with it) even if there is no other connection with England.

A German claimant, who had worked only in Germany for a UK-registered company under a contract governed by English law, was able to claim statutory holiday pay here. The EAT decided that the provisions of EU law from which statutory holiday rights derive are sufficiently precise and clear to be directly effective.

Where rights are directly effective, claims for breach of the EU source law rather than the derivative UK legislation can be brought against public body employers and UK legislation must be construed, if possible, to ensure there is an effective remedy for breach against private employers also.

The EAT disapplied the normal requirement for there to be a strong connection with Great Britain (see Lawson v Serco) to ensure that EU holiday rights could be claimed here.

The case opens the door for overseas employees to bring other claims derived from EU law here, if they can establish the direct effect of the relevant EU law and that UK law is capable of being construed in accordance with it. (Bleuse v MBT Transport Ltd, EAT).