The most significant change made by the 1986 Act arose from the decision in Marshall v Southampton and South-West Hampshire AHA (1986). The health authority had a policy which resulted in the dismissal of women because they had attained the State pension age, which is a different age for men and women. As a result Ms Marshall was forced to leave her employment; she then decided to challenge this policy. It is held by the ECJ that the term ‘dismissal’ in Art 5 of the Equal Treatment Directive must be given a wide meaning; that being so, the compulsory dismissal of workers pursuant to a policy concerning retirement related to conditions governing dismissal, which were then subject to Art 5. Where that policy then resulted in different retirement ages for men and women, there had been a contravention of the Article.