The Labour Court did not recommend a 2.5% pay increase for about 85 clerical workers at Cadbury (Ireland) PLC. The M.S.F. had argued that their pay should rise following changes to production workers' pay and hours. The Court found that the relationship between clerical salaries and production workers' hourly rates did not support the adjustment under the Programme for National Recovery. The recommendation was signed on 8 January 1990.