In the old days, before there were iPhone 4s or mobile phones in general, the person on garden leave was sometimes not allowed to travel far abroad (leaving his premises, or, simply, house) while he’s under house arrest, putting “garden leave” bluntly, that is. The old employer would, in fact, ask someone to call his home telephone from time to time during the day and during the night just to check if he is there.
To see if he’s actually at home, tending to his lovely bed of roses.
On garden leave.
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