Evenden v Guildford City FC [1975] QB 917
Employment law – Continuity of employment – Estoppel
Facts
Evenden was employed from 1955 to 1968 by the supporters club of Guildford City Football Club as a groundsman. The supporters club were a separate organisation to the football club. In November 1968, Evenden’s employment was transferred to the football club and he was given the same duties and all parties were under the impression that Evenden’s employment status would be continuous. In 1974, Evenden was made redundant by the football club. He then claimed for redundancy pay under the Redundancy Payments Act 1965 for his combined years of employment with the club, which he argued totalled 19 in all. The industrial tribunal only awarded him a sum based on six years of employment, since the transfer of employment. The industrial relations court dismissed his appeal. Evenden appealed again.
Issue
It was important for the court to consider the basis on which Evenden’s employment was transferred from the supporters club to the football club in 1968. Evenden looked to establish that there had been an agreement at that time that his employment was seen as continuous, which would have meant that he worked for the club for a total of nineteen years. The football club argued that Evenden, at that time, had begun working for a new employer and it was therefore not possible for Evenden to claim for the continuous employment.
Decision/Outcome
Evenden’s appeal was allowed and the decision of the industrial relations court was reversed. The court found that the football club had agreed, when his employment was transferred, that Evenden’s employment was continuous and on this basis, he could claim for the full 19 years he believed he was owed.
Updated 19 March 2026
This article accurately describes the facts, issue, and outcome of Evenden v Guildford City AFC Ltd [1975] QB 917, a Court of Appeal decision. The case remains good law as an authority on promissory estoppel and continuity of employment. However, readers should note several important statutory developments since 1975.
The Redundancy Payments Act 1965, under which the claim was brought, has been repealed and consolidated. Redundancy rights are now governed primarily by the Employment Rights Act 1996 (ERA 1996), and continuity of employment is addressed in Part XIV, Chapter I of that Act (sections 210–219). The Transfer of Undertakings (Protection of Employment) Regulations 2006 (SI 2006/246) (TUPE) are also now highly relevant to transfers of employment between associated employers, and in many modern cases a transfer of the kind described in Evenden would fall to be analysed under TUPE rather than through estoppel principles alone. Students should be aware that the estoppel reasoning in Evenden has been considered and distinguished in later cases, and that statutory protections now provide a more comprehensive framework than existed in 1975. The case retains value as an illustration of promissory estoppel in the employment context, but its practical significance has diminished given the modern statutory regime.
