TUPE: Post-transfer harmonisation dismissal did not entail "changes in the workforce"
In The Manchester College v Hazel and another EAT/0642/11 & EAT/0136/12, the EAT upheld a ruling by the employment tribunal that dismissals as a result of post-TUPE-transfer harmonisation were automatically unfair because they did not constitute an ETO reason "entailing changes in the workforce".