Deductions from wages: Advance commission set off against unlawful deduction

In Robertson v Blackstone Franks Investment Management Ltd [1998] IRLR 376, the Court of Appeal holds that an investment consultant suffered unlawful deductions from his wages when commission earned in respect of work done before his contract was terminated, but payable after termination, was not paid. However, in assessing the amount to which he was entitled, the employment tribunal had been wrong not to offset against the unlawful deductions a payment made as an advance against future commission by the employer to the consultant when he entered into the contract for services.