In many holiday pay claims, the failure to pay correct holiday pay can stretch back over many years. However, the scope for large historic holiday pay claims was severely curtailed by the EAT ruling in Bear Scotland (see page 182). In this case, the EAT ruled that historic holiday pay claims will fail if there has been a gap of three months or more between each holiday underpayment. In practice this means that in most cases, only the most recent holidays could be claimed for.