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Armour v Skeen [1977] IRLR 310.

A Director of Roads was convicted under s.37(1) for failing to produce the written safety policy as required of him by his employer. Whilst not a director in the true sense, he fell within the category ‘manager, secretary or other similar officer’. 


Liability is not fixed solely by job title; it is fixed according to the degree of authority and responsibility involved.

Also see: R v Chargot.