Defoe v HM Prison Service [2007] UKEAT 0451_06_0202 (2 February 2007)

Defoe v HM Prison Service [2007] UKEAT 0451_06_0202 (2 February 2007)

The Employment Tribunal correctly exercised its discretion in ordering disclosure of Security Information Reports in redacted form, as full disclosure of informant identities was unnecessary for the proper pursuit of the claim and the risks to the integrity of the intelligence system and safety of informants were well-founded.

Citation
[2007] UKEAT 0451_06_0202
Parties
Appellant: Mr Defoe; Respondent: Prison Service
Jurisdiction
United Kingdom
Judgment Date
02 February 2007
Procedural Posture
Employment Appeal Tribunal / Appeal Against Disclosure Order
Outcome
Appeal dismissed
Legal Topics
Disclosure, Race Discrimination, Disability Discrimination, Victimisation, Confidentiality, Constructive Dismissal
Employment Law Discrimination Law Civil Procedure Disclosure Race Discrimination Disability Discrimination Victimisation Confidentiality +1 more

Case Brief

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Parties

Mr Defoe

Appellant

Prison Service

Respondent

Procedural Posture

Employment Appeal Tribunal / Appeal Against Disclosure Order

Legal Issues

  1. 1 Whether the Employment Tribunal erred in ordering disclosure of Security Information Reports in redacted form
  2. 2 Whether full disclosure of informant identities is necessary for fair disposal of discrimination and victimisation claims
  3. 3 Balancing confidentiality and security risks against principles of full disclosure

Ratio Decidendi

The Employment Tribunal correctly exercised its discretion in ordering disclosure of Security Information Reports in redacted form, as full disclosure of informant identities was unnecessary for the proper pursuit of the claim and the risks to the integrity of the intelligence system and safety of informants were well-founded.

Court Disposition

Appeal dismissed

Orders

  • Disclosure of Security Information Reports to remain in redacted form as ordered by the Tribunal
  • No further disclosure of informant identities required