 The workfare element of the Work Programme was ruled "ultra vires" in a 2013 Court of Appeal judgment which stated that the Jobseeker's Allowance (Employment, Skills and Enterprise Scheme) Regulations 2011 did not describe the employment schemes to which they apply, as is required by the primary legislation.The Secretary of State for Work and Pensions Iain Duncan Smith responded to the Court of Appeal judgment by announcing emergency legislation in order to correct this.He also appeared to attack the utility of geology as a profession when attacking unemployed geology graduate Cait Reilly who had challenged the workfare scheme.