天美影院

The qualifications held or sought must relate to what is a recognised profession. This is apparent from the Court鈥檚 decision in the 鈥淐ommittee of Directors of Polytechnics鈥� (VTUPB4100). The members were all professionals because they held qualifications at degree level or equivalents. However, this did not satisfy this requirement of 鈥淚tem 1(b)鈥� because these were not qualifications in being a director of a polytechnic, a post for which no particular qualification was necessary or customary. Therefore, even had directorship of a polytechnic been found to be a 鈥減rofession鈥�, it is doubtful that the members鈥� qualifications would have been found to be 鈥渁ppropriate鈥�.

The qualifications should be obligatory or customary to enable the profession to be undertaken, and should be awarded by the association of which the holder is a member. In the 鈥淎ssociation of Payroll and Superannuation Administrators鈥�, membership of the Association was restricted to persons holding or seeking a Certificate in Payroll and Superannuation Administration. However, this qualification was awarded by the Chartered Institute of Public Finance and Accountancy (CIPFA). Successful candidates obtained neither membership of CIPFA nor any privileges relating to that body. They were not therefore qualified chartered accountants, but holders of a qualification that was concerned with a particular job within narrow confines and for which the qualification was neither obligatory nor customary.