Cases2303708/2022

Claimant v London Underground Limited

25 February 2025Before Employment Judge TuejeLondon Southin person

Outcome

Claimant fails

Individual claims

Whistleblowingfailed

The tribunal found that while the claimant made qualifying protected disclosures in April 2018 relating to fraud, health and safety breaches, and discrimination, none of the 19 alleged detriments were caused by or on the ground of those disclosures. In each instance where detriment was found (e.g. low performance rating, delayed feedback, breach of mediation agreement), the tribunal concluded these were either operationally justified, made by managers unaware of disclosure details, or genuine mistakes unconnected to the whistleblowing.

Facts

The claimant, a long-serving Trains Manager at London Underground, made protected disclosures in April 2018 alleging fraud, health and safety breaches, and discrimination by colleagues between 2010-2012. She alleged 19 separate detriments between May 2022 and July 2023, including negative performance ratings, blocked secondment applications, breach of a mediation agreement, and grievance outcomes that she claimed were in retaliation for her whistleblowing. The respondent denied the detriments were caused by the disclosures.

Decision

The tribunal found the claimant made seven qualifying protected disclosures in 2018. However, despite finding some detriments occurred (e.g. low performance rating, delayed feedback, breach of mediation agreement), the tribunal concluded none were caused by or on the ground of the protected disclosures. Managers either had no knowledge of disclosure details, acted for legitimate operational reasons, or made genuine mistakes unconnected to the whistleblowing. The claim was dismissed.

Practical note

A whistleblowing detriment claim fails if the tribunal finds the protected disclosure was not the causative reason for the treatment, even where some detriments are established and the disclosures themselves qualify for protection.

Legal authorities cited

Kilraine v London Borough of Wandsworth [2018] ICR 1850Cavendish Munro Professional Risks Management Ltd v Geduld [2010] ICR 325NHS Manchester v Fecitt & Others [2012] ICR 372Shamoon v Chief Constable of the Royal Ulster Constabulary [2003] ICR 337Chattenton v City of Sunderland City Council ET Case No.6402938/99Williams v Michelle Brown AM [2022] ICR 1231

Statutes

ERA 1996 s.48ERA 1996 s.47BERA 1996 s.43B

Case details

Case number
2303708/2022
Decision date
25 February 2025
Hearing type
full merits
Hearing days
5
Classification
contested

Respondent

Sector
transport
Represented
Yes
Rep type
barrister

Employment details

Role
Trains Manager

Claimant representation

Represented
No