the Bill of Rights, and therefore dismissed it. The Court of Appeal disagreed with that analysis. They held that "even on TerraNova's interpretation, the Act is not discriminatory", it merely narrows the scope of application the non-discrimination provision in the Bill of Rights. Employment Court's reliance on New Zealand's international obligations All parties acknowledged that the principles in the International Labour Organization (ILO) Convention Concerning Equal Remuneration for Men and Women Workers of Equal Value (Convention 100) extend beyond requiring equal pay for the same work. The Court of Appeal pointed to the presumption that Parliament does not intend to legislate contrary to New Zealand's international obligations, and therefore concluded that it is arguable that Parliament enacted the Equal Pay Act in order to comply with Convention 100, which it had ratified in 1983. However, given the general nature of the convention and the expansiveness of the interpretation of s 3(1)(b) of the Act that it supports, their Honours held that it was of limited use to them in deciding this case. Single source doctrine Their Honours briefly discussed a submission from the Attorney-General regarding the "single source" doctrine established by the European courts. They held that there was a certain logic to it, but were not persuaded of its use in this particular case. Significance Initially, little commentary existed on this case. It has been cited formally for its discussion of the New Zealand Bill of Rights Act 1990, as an authority for the general rule that subsequent statutes are irrelevant as an interpretive aid, and in relation to its discussion regarding the uniformity of language between two statutes. Martin Taylor of the Aged Care Association commented that the decision could have "catastrophic consequences for the sector if businesses were forced to pay workers a significant increase" as a result. Though it predates the TerraNova case, equal pay was also considered by the Human Rights Commission in May 2012. Upon the Appeal Court's decision, the government announced that it would negotiate with the unions and employers to settle the equal pay claims. In return, the Engineering, Printing and Manufacturing Union, which at the same time merged with the Service and Food Workers' Union to become E tū (Māori: stand tall), held off further legal action. The result of the negotiations was announced on 18 April 2017 by the Minister of Health, Jonathan Coleman. The settlement would result in pay