Met Office v. Edgar [2001] UKEAT 1448_00_1406 (14 June 2001)

Met Office v. Edgar [2001] UKEAT 1448_00_1406 (14 June 2001)

The Employment Tribunal has jurisdiction to hear complaints of victimisation under Section 47B of the Employment Rights Act 1996 where the detrimental act occurred after the Act came into force, even if the protected disclosure pre-dated the Act, as the statutory tort is not completed until the act of victimisation.

Citation
[2001] UKEAT 1448_00_1406
Parties
Appellant: Met Office; Respondent: Richard Edgar
Jurisdiction
United Kingdom
Judgment Date
14 June 2001
Procedural Posture
Employment Appeal / Appeal Against Preliminary Jurisdictional Ruling
Outcome
Appeal dismissed
Legal Topics
Protected Disclosure, Victimisation, Jurisdiction, Retrospective Effect of Legislation
Employment Law Protected Disclosure Victimisation Jurisdiction Retrospective Effect of Legislation

Case Brief

Summary, issues, holding and outcome

More case intelligence is available

Unlock the full research layer for this judgment.

Full judgment text Downloadable case file Legal principles 3 Authorities cited 10 Party arguments 2
Sign in to unlock

Parties

Met Office

Appellant

Richard Edgar

Respondent

Procedural Posture

Employment Appeal / Appeal Against Preliminary Jurisdictional Ruling

Legal Issues

  1. 1 Whether the Employment Tribunal has jurisdiction to hear a complaint of victimisation based on a protected disclosure made before the relevant legislation came into force

Ratio Decidendi

The Employment Tribunal has jurisdiction to hear complaints of victimisation under Section 47B of the Employment Rights Act 1996 where the detrimental act occurred after the Act came into force, even if the protected disclosure pre-dated the Act, as the statutory tort is not completed until the act of victimisation.

Court Disposition

Appeal dismissed

Orders

  • Employment Tribunal's jurisdictional ruling affirmed
  • Cross appeal not considered