Goods stacked on the shelves in a self-service shop can be subject of the material liability agreement
Goods that are stored in a shop are, by their nature, intended for turnover or circulation, irrespective of which part of the shop they are in. Employee does not lose the possibility of personal disposition of goods merely because they are „stacked“ on the shelves of a self-service shop. Section 252 Article 1 of the Labour Code contains only non-exhaustive list of values related to material responsibility. The "personal disposition" option is not exhausted exclusively by the option where the responsible employee excludes other persons from the possibility to dispose of the goods, but also when the goods are accessible in such a way that customers can choose and serve themselves under the supervision of a responsible employee.
(Judgement of the Supreme Court 21 Cdo 492/2019 of 23 July 2019)