Mr P Jackson v Serious Fraud Office — 2025

The tribunal found that the claimant's first alleged protected disclosure, made during the 31 October 2023 team meeting, was not a qualifying disclosure within s.43B ERA 1996. It held that he was expressing disagreement with Mr McLaughlin's instruction and his own interpretation of CPIA disclosure duties, rather than disclosing information with sufficient factual content and specificity. The tribunal also found that he did not reasonably believe he was making a protected disclosure or that the instruction amounted to a breach of legal obligation.\n\nOn the facts, the tribunal accepted the evidence of Mr McLaughlin, Ms Chouraqui, Mr Duff and Mr Pritchard that a meeting took place in early November 2023 about staffing and the claimant's temporary promotion. It found that staffing levels had improved and that Ms Chouraqui decided, for operational reasons, not to extend the temporary PI promotion beyond the end of November 2023. The tribunal rejected the claimant's case that Mr McLaughlin alone made the decision or that the promotion ended because of protected disclosures.\n\nThe tribunal rejected the alleged detriments said to follow from the disclosure, including the suggestion that Mr McLaughlin belittled the claimant in the 31 October meeting, that the 13 November meeting was disciplinary, that the redistribution of work was punitive, that the claimant's reputation was damaged, and that later remarks on 30 November 2023 were improper detriments. It also rejected the grievance-related complaints, finding that the matters raised with Mr Emson, Mr Gallagher and Ms Greenwood were handled through a reasonable process and that no demonstrable detriment was shown.\n\nThe breach of contract claim also failed. The tribunal held that the claimant's temporary promotion was always finite and that when it ended, the associated entitlement to the higher pay and pension contributions ended as well. Although the claim was presented out of time, the tribunal extended time under s.48(3) ERA 1996 because it was brought shortly after expiry and the claimant had reasonably treated 1 December 2023 as the end date.