Before 2008, it was generally accepted that the existence of a contract of employment
between employer and employee was an essential requirement for the validity of an
employment relationship. After 2008 this requirement was questioned in a number of
cases and also abandoned in amendments to the Labour Relations Act. However, towards
the end of 2015 the Labour Appeal Court in the Universal Church case restored the previous
legal position and stated clearly that an employment relationship is by its very
nature dependent on a contractual working arrangement.