Whilst it was held that a two year qualifying period for unfair dismissal complaints had a disparately adverse impact on women so as to amount to indirect discrimination contrary to Art 141 (formerly 119), the House of Lords concluded that the Secretary of State had objectively justified the requirement by providing evidence that to reduce the requirement might inhibit the recruitment of employees and had shown that it was unrelated to any discrimination based on sex. For a critique of Seymour-Smith, see Townshend-Smith, R, ‘Seymour-Smith: the closing stages’ (2000) 29ILJ 297.