Lord Wilberforce reviewed the authorities and adopted a tripartite distinction.

Lord Wilberforce was chancellor of the University from 1978 until 1994.

Lord Wilberforce held it was a necessary term of living on an estate that landlords keep stairwells in order.

The reference to an "associated" person was made by Lord Wilberforce (at p989).

In the same case Lord Wilberforce said, at p. 1027:

Her failure to do so brings the case within the second of Lord Wilberforce's amplifications.

Lord Wilberforce, however, did not see the rule as applying in all circumstances:

Lord Wilberforce discovered that there were two factors in any possible wage increase.

The important facts are set out in the following quotation from Lord Wilberforce:.

Part of Lord Wilberforce's test is extremely difficult for the practitioner to apply.