High Quality Content by WIKIPEDIA articles! R (Seymour-Smith) v Secretary of State for Employment UKHL 12 and (1999) C-167/97 is a landmark case in UK labour law and European labour law on the qualifying period of work before an employee accrues unfair dismissal rights. It was held by the House of Lords and the European Court of Justice that a two year qualifying period had a disparate impact on women given that significantly fewer women worked long enough to be protected by the unfair dismissal law, but that the government could, at that point in the 1990s, succeed in an objective justification of increasing recruitment by employers.