In a case involving London Underground, the Court of Appeal found in favour of a tube driver who was injured by the “dead man’s handle” brake on trains. It found London Underground had failed to carry out a risk assessment and to train RMT transport union member Ms Allison, contrary to the requirements of PUWER. The case provided important guidance on the duty to ensure that workers who use work equipment receive adequate health and safety training and established that the duty to provide training is mandatory.