The probationary nature of an employment contract does not provide a meaningful basis for distinguishing Barker so as to imply a term of mutual trust and confidence by necessity. Where a statutory and industrial regime comprehensively regulates the employment relationship, including grievance procedures, neither a term of mutual trust and confidence nor a stand-alone term of good faith will be implied by necessity. Aspirational guidelines in a handbook described as 'suggested criteria' are not incorporated into employment contracts where they were not shown to employees before appointment and are not promissory in nature.
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