Employment – Payment. Arrears of pay arising from an equal pay claim under the Equal Pay Act 1970, that had not yet been determined, constituted arrears of pay under the Employment Rights Act 1996. The Court of Appeal, Civil Division, held that the claims were for arrears of pay, each of them was a debt to which Part XII of the Employment Rights Act 1996 applied. Accordingly the Secretary of State was required to pay each claimant the amount to which she was entitled in respect of that debt.