Cases3306292/2024

Claimant v Royal Mail Group Limited

24 October 2025Before Employment Judge L RobertsonCambridgeremote video

Outcome

Claimant fails

Individual claims

Whistleblowingstruck out

The whistleblowing detriment complaint regarding the Greenford OPL temporary vacancy in early 2023 was struck out as out of time. The tribunal found that while it was not reasonably practicable to present the claim within the primary time limit (as the claimant was not aware of the alleged detriment until early 2024), the claim was not presented within a further reasonable period. The claimant delayed almost 2 months after learning of the detriment before commencing ACAS early conciliation, and took a further 4 weeks after early conciliation ended to present his claim, which the tribunal found objectively unreasonable given the claimant knew of applicable time limits by 12 December 2023 and was specifically advised by his union on 8 April 2024.

Detrimentstruck out

The second alleged detriment (dated 22 May 2022) was also struck out as out of time. The tribunal found the same time limit issues applied to this complaint pursuant to section 48 ERA. The tribunal concluded that the complaint was not presented within the applicable time limit, and while it was not reasonably practicable to do so, the complaint was not presented within a further reasonable period.

Facts

The claimant worked for Royal Mail and applied for voluntary redundancy in April 2022 which was refused. He was on long-term sickness absence from around May 2022 suffering from depression and anxiety. He alleged two whistleblowing detriments: one on 22 May 2022 and another in early 2023 when he was not offered a temporary vacancy for the Greenford OPL role. He was not aware of the second alleged detriment until early 2024. He raised a grievance on 3 August 2022 which went through internal processes concluding in December 2023. He had trade union representation throughout. He commenced ACAS early conciliation on 20 April 2024 and filed his claim on 29 June 2024.

Decision

The tribunal struck out the whistleblowing detriment complaints as out of time. While it found it was not reasonably practicable to present the claim within the primary time limit (as the claimant was not aware of one alleged detriment until after the time limit expired), the tribunal found the claim was not presented within a further reasonable period. The claimant knew of applicable time limits by December 2023 and was specifically advised by his union on 8 April 2024, but delayed almost 2 months before starting early conciliation and a further 4 weeks after early conciliation ended to file his claim.

Practical note

Knowledge of time limits starts the clock for what constitutes a 'reasonable further period' even in whistleblowing cases: claimants aware they are out of time must act with particular urgency, and delays of weeks after learning of time limits will be fatal.

Legal authorities cited

Porter v Bandridge Ltd [1978] IRC 943Norbert Dentressangle Logistics Ltd v Hutton EATS 0011/13Palmer v Southend-on-Sea Borough Council [1984] ICR 372Marks and Spencer plc v Williams-Ryan [2005] EWCA Civ 470Schultz v Esso Petroleum Co Ltd [1999] ICR 1202Bodha v Hampshire Area Health Authority [1982] ICR 200Walls Meat Co Ltd v Khan [1978] IRLR 499University Hospitals Bristol NHS Foundation Trust v Williams EAT 0291/12Cullinane v Balfour Beatty Engineering Services Ltd EAT 0537/10Asda Stores Ltd v Kauser EAT 0165/07

Statutes

ERA 1996 s.47BERA 1996 s.48

Case details

Case number
3306292/2024
Decision date
24 October 2025
Hearing type
preliminary
Hearing days
1
Classification
contested

Respondent

Sector
logistics
Represented
Yes
Rep type
solicitor

Employment details

Role
CCOM

Claimant representation

Represented
No