Whistleblowing - Michelmores Employment Law Update

Those of you who attended our Autumn Conferenceand then told the Head Teacher what he had done.
in 2006 may be interested to learn of some recentFor his trouble, he received a written warning on the
developments in the area of whistleblowing - that is,grounds of misconduct for breaking into the system
claims of suffering a detriment or dismissal on accountwithout authority. In response to this he resigned,
of making a protected disclosure under the Publicclaiming that he had been subjected to a detriment
Interest Disclosure Act 1998 (PIDA).and constructively dismissed for making a protected
The scope of PIDAdisclosure.
The case of Croke v Hydro Aluminium Worcester LtdThe Employment Tribunal accepted that there had
concerned an individual who supplied his services to anbeen a qualifying disclosure under PIDA because the
employment agency through his own serviceteacher reasonably believed that his employer was
company. The employment agency, in turn, supplied thelikely to be in breach of its legal obligation under the
services of that company to an end user client.Data Protection Act 1998. The Tribunal further decided
Despite this very commercial arrangement, thethat the teacher's conduct in breaking into the system
Employment Appeal Tribunal (EAT) held that thewas so interrelated to his original disclosure that it
individual was a "worker" for the purposes of sectionshould be considered to be "part and parcel of it".
43K of the Employment Rights Act 1996 (ERA) (whichAccording, as the teacher had clearly suffered a
incorporates provisions of PIDA). The individual wasdetriment on account of such conduct, his claim was
therefore entitled to bring a claim that he had sufferedupheld.
a detriment (in this case the termination of thisHowever, both the EAT and now the Court of Appeal
contract) on the grounds that he had made ahave rejected this analysis. The EAT drew an
protected disclosure.important distinction between the disclosure of
Reasonable Beliefinformation itself (which is protected) and the conduct
To gain protection under the PIDA, a worker need onlydesigned to demonstrate that a particular belief was
hold a reasonable belief that the information disclosedreasonable (which is not). Put simply, E was disciplined
tends to show one of the "relevant failures" underfor his actions in hacking into the system, not for
s.43B ERA (e.g. that a criminal offense was beinginforming the school that its system was insecure. A
committed, that the employer was in breach of a legalworker is not permitted to commit what would
obligation, or that there was a risk to health and safetyotherwise be an act of misconduct in order to justify a
or the environment). If the worker is ultimately showndisclosure.
to be wrong, this will not be fatal to his whistleblowingComment
claim, providing that the mistake was reasonable.Whilst the EAT's reasoning is persuasive, it does
In 2004, the case of Kraus v Penna plc & anorreveal a weakness in the whistleblowing legislation. If a
imposed a controversial limitation on the concept ofworker's actions in investigating suspected malpractice
reasonable belief. The EAT in that case held that,are not protected, it may be difficult to establish a
although a whistleblower's claim will not be defeated ifsufficient "reasonable belief" to ensure that any
he is reasonably mistaken about the factual basis ofsubsequent disclosure is protected. This will deter
the alleged malpractice, the claim will fail if, as a matterpotential whistleblowers from coming forward and
of law, the employer was not actually under any legalundermine the purpose of the legislation.
obligation in the first place, or the alleged act(s) couldCommentators have suggested that one solution may
not amount to a criminal offence.be to soften the statutory test so as to only require a
This is a subtle but important distinction which has"genuine belief" (subjective test) or a "reasonable
recently been examined by the Court of Appeal in thesuspicion".
case of Babula v Waltham Forest College. Mr BabulaWhilst employers will welcome this decision, it is not a
was a lecturer on a business course who discovered"get out of jail free card". Tribunals will be wary of
that his predecessor, Mr Jalil, had not taught the courseemployers alleging that an employee was dismissed
curriculum but had divided the class into an Islamicbecause of an act related to a disclosure rather than
group (to whom he taught religious studies) and athe disclosure itself and employers running this
non-Islamic group (which he ignored). He had also toldargument can expect a thorough examination of their
the Islamic group that he wished that a terroristunderlying motives.
incident, similar to September 11, would occur in London.AND IN OTHER NEWS
Mr Babula reported these allegations to the Head ofReligion (or a lack thereof) has featured heavily in a
School but subsequently resigned, claiming that he hadnumber of recent employment law cases.
been subjected to a number of detrimental acts as aIn the highly publicised case of Azmi v Kirklees
result of raising his concerns.Metropolitan Borough Council, Mrs Azmi has lost her
In pursuing a claim for automatic unfair dismissal underappeal regarding her right to wear a veil whilst
PIDA, Mr Babula sought to establish that he had madeperforming her duties as a bilingual support teacher.
a protected disclosure on the following grounds:-The EAT found that an instruction to remove the veil
That he reasonably believed that a criminal offence ofwas neither directly or indirectly discriminatory on the
incitement to racial hatred had been committed; andgrounds of religion or belief. Although the instruction
That the College had failed to comply with a legalmet the criteria for indirect discrimination, the EAT held
obligation by failing to implement it's equal opportunitiesthat the employer was entitled to rely upon the
policy against those who discriminate on the groundsdefence of 'objective justification' - the instruction being
of religion.a proportionate means of achieving a legitimate aim
Applying the strict test in Kraus, the Tribunal and the(namely, the provision of the best quality education).
EAT concluded that Mr Babula failed on both of theseIn Glasgow City Council v McNab an atheist teacher
grounds. Firstly, the alleged actions of Mr Jalil wereworking in a local authority-maintained Roman Catholic
undertaken on the grounds of religion, not race, and atschool sought a promotion to the position of 'principle
the time, there was no such offence to incitement toteacher of pastoral care'. However, he was refused
religious hatred. Secondly, the Respondent's equalan interview on the grounds that being of Roman
opportunity made no reference to religiousCatholic faith was a prerequisite for the post in
discrimination and so no legal obligation wasquestion. The Council accepted that it had discriminated
established. According to Kraus, Mr Babula'sagainst Mr McNab but sought to rely upon the "genuine
reasonable beliefs were irrelevant if no criminaloccupational requirement" defence contained in the
offence or legal obligation actually existed.Religion or Belief Regulations. In rejecting the Council's
However, the Court of Appeal thought otherwise.argument, the EAT held that the responsibilities of a
Overturning the decision in Kraus, the Court ruled thatpastoral care teacher involved giving advice upon a
such a restrictive interpretation would undermine thelarge number of issues, not simply the teachings of the
whole purpose of the whistleblowing legislation, which isRoman Catholic Church (which could be delegated to
to encourage workers to come forward on the basisanother teacher). It followed that it was not a genuine
of their reasonable beliefs - not their legal expertise. Mrrequirement for the post holder to be of Roman
Babula therefore won his appeal.Catholic faith and the Council had unlawful
Breaking the Chain of Causationdiscriminated against Mr McNab.
In order to succeed in a claim under the PIDA, aFinally, in New Testament Church of God v Stewart,
worker must prove causation i.e. that the relevantthe EAT has confirmed that a minister of religion can
detriment or dismissal was a direct result of havingbring a claim for unfair dismissal as they are employed
made a protected disclosure. The case of Boltonunder a contract of employment. In rejecting the
School v Evans involved an information technologytraditional view that a cleric is merely "a servant of
teacher who was concerned about the security of theGod", the EAT held that: "if the relationship between
School's new IT system. His initial concerns were notchurch and minister has many of the characteristics of
addressed and so to demonstrate the system'sa contract of employment in terms of rights and
potential weaknesses, he hacked into it from aobligations, these cannot be ignored simply because
student's computer, disabled some of the accountsthe duties are of a religious or pastoral nature.