Georgina Jane Gibbon v BG Solicitors LLP — 2025

The second claim, numbered 2601823/2024, was a victimisation complaint arising from the respondent’s report to the Solicitors Regulation Authority on 11 June 2024. The tribunal heard oral evidence on limitation, found that the claimant was aware of the report on 13 August 2024, and held that the claim had been presented out of time. Applying section 123 Equality Act 2010 and the just and equitable discretion, the tribunal extended time because the delay was relatively short and there was little prejudice to the respondent.

The tribunal then held that the report to the SRA was subject to absolute privilege and immunity from suit, relying on White v Southampton University Hospitals NHS Trust and William Roche and related authority. It accepted the respondent’s submission that a complaint to the Employment Tribunal could not be founded on that report, and struck out the second claim under Rule 38(1)(a) because it had no reasonable prospect of success.

Had the claim not been struck out, the tribunal said it would in any event have regarded it as having little reasonable prospect of success because solicitors are under a duty to report potential misconduct to the SRA, the initial letter used the term “FE” rather than naming the claimant, and the matter concerned an alleged misuse of a Deputyship Order. No deposit order was made, although the tribunal said it would have ordered a £1,000 deposit and considered that the claimant had sufficient means to justify that amount.