Background
In Mr P J Jackson v The Chief Constable of Greater Manchester Police, the claimant was a former senior police officer for Greater Manchester Police. He sent three reports to the independent police regulator alleging a culture of cronyism, favouritism and cover-ups. He alleged that specific passages within those reports amounted to 19 protected disclosures, that he suffered detriment as a result, and that he was constructively dismissed when he gave notice of his retirement.
The employment tribunal found that none of the 19 alleged disclosures were a protected disclosure, and that the claimant had not been constructively dismissed. The claimant appealed in relation to six of the disclosures and the constructive dismissal finding.
EAT decision
The Employment Appeal Tribunal (EAT) dismissed the appeal on all grounds. The claimant argued that the tribunal should have confined its analysis to the specific passages he chose to plead, treating the surrounding material only as background context.
The EAT rejected that approach. Disclosures made outside the employment relationship, to a prescribed person such as a regulator require a higher threshold to be met. Under the relevant provision, the claimant was required to reasonably believe both that the information disclosed in relation to each alleged protected disclosure, and that every allegation in it, was substantially true. It was not sufficient for the claimant to reasonably believe the general gist of what was...
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