 But it will not apply to professional self-employed people at the top end of the labour market, and it is uncertain whether it always applies to those working through agencies and those whose jobs make them vulnerable.Section 139 of the Act was at issue in ‘’Murray v Foyle Meats Ltd’’ (1999), where the House of Lords determined that an employee’s responsibilities as defined in their employment contract were not at issue when a lawful redundancy procedure was undertaken, but what the employee’s actual day-to-day responsibilities are.Section 20 of the act was at issue in "Cairns v Visteon UK Ltd" (2007) where the Employment Appeal Tribunal held that an agency worker could not claim unfair dismissal.