Equal pay: Immediate successor can be comparator

In Diocese of Hallam Trustee v Connaughton [1996] IRLR 505, the EAT holds that an industrial tribunal had jurisdiction to hear a woman's complaint that she was being paid less than she would have been paid if she were a man doing equal work for the same employer. She could not point to a contemporaneous or immediately preceding male comparator, but that did not prevent her from inviting the tribunal to hear her complaint by reference to her male successor as a notional contemporaneous comparator. The successor's contract of employment was arguably so proximate to her own as to make him an effective comparator.