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employers must act with caution With continued uncertainty surrounding the health benefits or consequences of electronic cigarettes, employers need to err on the side of caution. The health implications of "vaping" are not yet known and businesses are in the dark as to whether the e-cigarette will help or hinder individual employees. In the latest development, the anti-tobacco charity Ash (Action on Smoking and Health) has released research highlighting that the number of e-cigarette smokers has increased from 700,000 to 2 million in the past two years. Furthermore, the research shows that a third of users are ex-smokers and two thirds are existing smokers. Published: December 23, 2015 Thevarajah v Riordan and Others Before Lord Neuberger of Abbotsbury, Lord Mance, Lord Clarke of Stone-cum-Ebony, Lord Sumption and Lord Hodge Judgment: December 16, 2015 Where a party to litigation had been barred from defending a claim because he had failed to comply with an "unless" order to do something within a specified time and relief from sanctions had been refused at a time when he was still in default, the fact that he subsequently complied with the unless order did not amount to a material change of circumstances entitling him to make a second application for relief from sanctions

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