Sarnoff v YZ [2021] EWCA Civ 26 (15 January 2021)

Sarnoff v YZ [2021] EWCA Civ 26 (15 January 2021)

The Employment Tribunal has power under rule 29 to order disclosure against parties regardless of their location; rule 31 applies only to non-parties. The appeal is dismissed as the Tribunal acted within its powers.

Citation
[2021] EWCA Civ 26
Parties
Appellant: Tim Sarnoff; Respondent: YZ
Jurisdiction
England and Wales
Judgment Date
15 January 2021
Procedural Posture
Appeal From Employment Appeal Tribunal / Court of Appeal Judgment
Outcome
Appeal dismissed
Legal Topics
Disclosure of Documents, Case Management Powers, Jurisdiction of Employment Tribunal, Interpretation of Tribunal Rules
Employment Law Civil Procedure Disclosure of Documents Case Management Powers Jurisdiction of Employment Tribunal Interpretation of Tribunal Rules

Case Brief

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Parties

Tim Sarnoff

Appellant

YZ

Respondent

Procedural Posture

Appeal From Employment Appeal Tribunal / Court of Appeal Judgment

Legal Issues

  1. 1 Whether Employment Tribunal can order disclosure against a party not in Great Britain
  2. 2 Interpretation of Rules 29 and 31 of the Employment Tribunal Rules of Procedure

Ratio Decidendi

The Employment Tribunal has power under rule 29 to order disclosure against parties regardless of their location; rule 31 applies only to non-parties. The appeal is dismissed as the Tribunal acted within its powers.

Court Disposition

Appeal dismissed

Orders

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