Sarnoff v YZ

Sarnoff v YZ

The Employment Tribunal has power under rule 29 to make disclosure orders against parties regardless of their location; rule 31 is limited to non-parties, and the geographical limitation does not apply to parties.

Parties
Appellant: Tim Sarnoff; Respondent: YZ
Jurisdiction
England and Wales
Judgment Date
15 January 2021
Procedural Posture
Appeal / Court of Appeal Judgment
Outcome
Appeal dismissed
Legal Topics
Disclosure Orders, Jurisdiction, Case Management Powers
Employment Law Civil Procedure Disclosure Orders Jurisdiction Case Management Powers

Case Brief

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Parties

Tim Sarnoff

Appellant

YZ

Respondent

Procedural Posture

Appeal / Court of Appeal Judgment

Legal Issues

  1. 1 Whether the Employment Tribunal has power to make disclosure orders against parties not in Great Britain
  2. 2 Interpretation of Employment Tribunal Rules regarding disclosure
  3. 3 Scope of case management powers under rule 29

Ratio Decidendi

The Employment Tribunal has power under rule 29 to make disclosure orders against parties regardless of their location; rule 31 is limited to non-parties, and the geographical limitation does not apply to parties.

Court Disposition

Appeal dismissed

Orders

  • The appeal is dismissed.
  • No order as to costs.