Case 2218585/2024 · Employment Tribunal
Claimant v The Commissioner of Police of the Metropolis — 2025
- Case reference
- 2218585/2024
- Decision date
- 11 August 2025
- Jurisdiction
- England & Wales
- Judge
- Employment Judge Lewis
Parties
2 namedClaimant
Claimant
Key findings
Tribunal's reasoningThe two Claimants, former Metropolitan Police Constables, brought complaints against the Commissioner of Police of the Metropolis of detrimental treatment on whistleblowing grounds under ss 47B and 48(1A) of the Employment Rights Act 1996, and of 'automatically' unfair dismissal on whistleblowing grounds under s 103A. The matter was heard over fifteen days in July 2025 before Employment Judge A M Snelson sitting alone at London Central, with counsel appearing for both sides.
The Tribunal determined that none of the complaints were well-founded. The complaints of detrimental treatment by both Claimants under ss 47B and 48(1A), and their complaints of automatically unfair dismissal under ss 103A and 111(1), were each found not well-founded on their merits. To the extent that the detrimental treatment complaints were presented outside the statutory three-month period (as extended by Early Conciliation), they additionally failed on the further ground that they were out of time and the Tribunal had no jurisdiction to consider them.
Accordingly, the proceedings as a whole were dismissed. The parties had been notified on 17 July 2025 that the claims had failed and that no remedies hearing would be required.
Claims and outcomes
4 findings recorded| Claim type | Issue or finding | Outcome | Protected characteristic | Award |
|---|---|---|---|---|
| Whistleblowing | First Claimant (Mr Kiddle) complaints of detrimental treatment under ss 47B and 48(1A) ERA 1996 not well-founded; some also failed on time-based jurisdictional grounds (out of time). | Dismissed | — | — |
| Unfair dismissal | First Claimant (Mr Kiddle) complaint of 'automatically' unfair dismissal under ss 103A and 111(1) ERA 1996 not well-founded. | Dismissed | — | — |
| Whistleblowing | Second Claimant (Mr Seabright) complaints of detrimental treatment under ss 47B and 48(1A) ERA 1996 not well-founded; some also failed on time-based jurisdictional grounds (out of time). | Dismissed | — | — |
| Unfair dismissal | Second Claimant (Mr Seabright) complaint of 'automatically' unfair dismissal under ss 103A and 111(1) ERA 1996 not well-founded. | Dismissed | — | — |
Legal tests applied
14 references- s.43B ERA 1996
- s.43C ERA 1996
- s.43KA ERA 1996
- s.47B ERA 1996
- s.48(1A) ERA 1996
- s.48(2) ERA 1996
- s.48(3) ERA 1996
- s.103A ERA 1996
- s.111(1) ERA 1996
- Cavendish Munro Professional Risk Management Ltd v Geduld [2010] ICR 325
- Kilraine v London Borough of Wandsworth [2018] ICR 1850 CA
- Shamoon v Chief Constable of the RUC [2003] IRLR 285 HL
- Osipov v International Petroleum Ltd UKEAT/0058/17/DA
- Palmer v Southend-on-Sea BC [1984] ICR 372 CA
Official outcome judgment PDF
Gov.uk primary recordThe official judgment PDF on gov.uk contains the tribunal's outcome, reasoning, and any remedy details. Where this page does not yet show extracted outcomes for every claim, use the PDF as the authoritative source.
Published on gov.uk under the Open Government Licence v3.0.
How we got this data
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