P was sacked because he couldn’t cope with new practices required by the new owners of a business, including increased paperwork and giving estimates to customers in advance. P then employed a new manager. D argued that he had been made redundant and was therefore entitled to redundancy payment. Divisional Court rejected this claim, saying that the requirement of greater efficiency did not correspond to any of the circumstances that might indicate redundancy (reduction of work, cessation of business, reduction of a kind of work etc). There was merely a need for a workshop manager with different skills, not a loss of the need for a manager.
Widgery J: There is a difference between requiring a new kind of work (he says that if car manufacturers start using metal instead of wood, then the woodworkers may become redundant) and greater efficiency in the same kind of work.