Dryden v Greater Glasgow Health Board [1992] IRLR 469 is a UK labour law case concerning the contract of employment.

Lord Coulsfield in the Edinburgh Employment Appeal Tribunal held that a unilateral variation on the workplace rules did not amount to a breach of any contract term.

Before turning to these contentions, however, we should first deal with the question whether the contract contained any specific implied term related to smoking, a matter in respect of which we were left in some uncertainty about the appellant's position.

The question whether a term should be implied in a particular contract is one dependent on the particular facts and circumstances, and, while we think that there is much force in the reasoning of the Industrial Tribunal, it seems to us that they went further than is necessary for the decision of this case.

It is sufficient, in our opinion, to say that the findings of fact and submissions before us form an entirely inadequate basis for holding that there was any implied contract term to the effect that smoking would, to some extent or in some way, continue to be permitted, either generally or in the particular case of the appellant.

Neither before us, nor, it appears, before the Industrial Tribunal, was there any real attempt to present an argument for the existence of an implied term related to the well-established tests which have to be applied in order to determine whether or not such a term should be held to form part of a contract, nor was there any real attempt to lead evidence to establish the facts necessary to found such an argument.