Carlo breen succeeds in persuading an employment tribunal in the first litigated case of its kind, that the white book job evaluation in local authorities, which dictates rates of pay for male employees, should be displaced, on the basis that the representative job has fundamentally changed. In equal pay cases it had always been generally accepted that jobs within the white book are rated as equivalent. This decision sets the marker for councils to argue to the contrary. In the enormity of equal pay litigation relating to GMF defences, this gives local authorities the option to request a preliminary hearing on this single issue, which can if successful, strike out several claimant groups.