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Whistleblowing - Michelmores Employment Law Update

Those of you who attended our Autumnit from a student's computer, disabled some
Conference in 2006 may be interested to learnof the accounts and then told the Head
of some recent developments in the area ofTeacher what he had done. For his trouble, he
whistleblowing - that is, claims of sufferingreceived a written warning on the grounds of
a detriment or dismissal on account of makingmisconduct for breaking into the system
a protected disclosure under the Publicwithout authority. In response to this he
Interest  Disclosure  Act  1998  (PIDA).resigned, claiming that he had been subjected
to a detriment and constructively dismissed
The  scope  of  PIDAfor  making  a  protected  disclosure.
The case of Croke v Hydro Aluminium WorcesterThe Employment Tribunal accepted that there
Ltd concerned an individual who supplied hishad been a qualifying disclosure under PIDA
services to an employment agency through hisbecause the teacher reasonably believed that
own service company. The employment agency,his employer was likely to be in breach of
in turn, supplied the services of thatits legal obligation under the Data
company to an end user client. Despite thisProtection Act 1998. The Tribunal further
very commercial arrangement, the Employmentdecided that the teacher's conduct in
Appeal Tribunal (EAT) held that thebreaking into the system was so interrelated
individual was a "worker" for the purposes ofto his original disclosure that it should be
section 43K of the Employment Rights Act 1996considered to be "part and parcel of it".
(ERA) (which incorporates provisions ofAccording, as the teacher had clearly
PIDA). The individual was therefore entitledsuffered a detriment on account of such
to bring a claim that he had suffered aconduct,  his  claim  was  upheld.
detriment (in this case the termination of
this contract) on the grounds that he hadHowever, both the EAT and now the Court of
made  a  protected  disclosure.Appeal have rejected this analysis. The EAT
drew an important distinction between the
Reasonable  Beliefdisclosure of information itself (which is
protected) and the conduct designed to
To gain protection under the PIDA, a workerdemonstrate that a particular belief was
need only hold a reasonable belief that thereasonable (which is not). Put simply, E was
information disclosed tends to show one ofdisciplined for his actions in hacking into
the "relevant failures" under s.43B ERA (e.g.the system, not for informing the school that
that a criminal offense was being committed,its system was insecure. A worker is not
that the employer was in breach of a legalpermitted to commit what would otherwise be
obligation, or that there was a risk toan act of misconduct in order to justify a
health and safety or the environment). If thedisclosure.
worker is ultimately shown 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 reveal a weakness in the whistleblowing
In 2004, the case of Kraus v Penna plc & anorlegislation. If a worker's actions in
imposed a controversial limitation on theinvestigating suspected malpractice are not
concept of reasonable belief. The EAT in thatprotected, it may be difficult to establish a
case held that, although a whistleblower'ssufficient "reasonable belief" to ensure that
claim will not be defeated if he isany subsequent disclosure is protected. This
reasonably mistaken about the factual basiswill deter potential whistleblowers from
of the alleged malpractice, the claim willcoming forward and undermine the purpose of
fail if, as a matter of law, the employer wasthe legislation. Commentators have suggested
not actually under any legal obligation inthat one solution may be to soften the
the first place, or the alleged act(s) couldstatutory test so as to only require a
not  amount  to  a  criminal  offence."genuine belief" (subjective test) or a
"reasonable  suspicion".
This is a subtle but important distinction
which has recently been examined by the CourtWhilst employers will welcome this decision,
of Appeal in the case of Babula v Walthamit is not a "get out of jail free card".
Forest College. Mr Babula was a lecturer on aTribunals will be wary of employers alleging
business course who discovered that histhat an employee was dismissed because of an
predecessor, Mr Jalil, had not taught theact related to a disclosure rather than the
course curriculum but had divided the classdisclosure itself and employers running this
into an Islamic group (to whom he taughtargument can expect a thorough examination of
religious studies) and a non-Islamic grouptheir  underlying  motives.
(which he ignored). He had also told the
Islamic group that he wished that a terroristAND  IN  OTHER  NEWS
incident, similar to September 11, would
occur in London. Mr Babula reported theseReligion (or a lack thereof) has featured
allegations to the Head of School butheavily in a number of recent employment law
subsequently resigned, claiming that he hadcases.
been subjected to a number of detrimental
acts  as  a  result  of raising his concerns.In the highly publicised case of Azmi v
Kirklees Metropolitan Borough Council, Mrs
In pursuing a claim for automatic unfairAzmi has lost her appeal regarding her right
dismissal under PIDA, Mr Babula sought toto wear a veil whilst performing her duties
establish that he had made a protectedas a bilingual support teacher. The EAT found
disclosure  on  the  following  grounds:-that an instruction to remove the veil was
neither directly or indirectly discriminatory
That he reasonably believed that a criminalon the grounds of religion or belief.
offence of incitement to racial hatred hadAlthough the instruction met the criteria for
been  committed;  andindirect discrimination, the EAT held that
the employer was entitled to rely upon the
That the College had failed to comply with adefence of 'objective justification' - the
legal obligation by failing to implement it'sinstruction being a proportionate means of
equal opportunities policy against those whoachieving a legitimate aim (namely, the
discriminate  on  the  grounds  of  religion.provision  of  the  best  quality education).
Applying the strict test in Kraus, theIn Glasgow City Council v McNab an atheist
Tribunal and the EAT concluded that Mr Babulateacher working in a local
failed on both of these grounds. Firstly, theauthority-maintained Roman Catholic school
alleged actions of Mr Jalil were undertakensought a promotion to the position of
on the grounds of religion, not race, and at'principle teacher of pastoral care'.
the time, there was no such offence toHowever, he was refused an interview on the
incitement to religious hatred. Secondly, thegrounds that being of Roman Catholic faith
Respondent's equal opportunity made nowas a prerequisite for the post in question.
reference to religious discrimination and soThe Council accepted that it had
no legal obligation was established.discriminated against Mr McNab but sought to
According to Kraus, Mr Babula's reasonablerely upon the "genuine occupational
beliefs were irrelevant if no criminalrequirement" defence contained in the
offence or legal obligation actually existed.Religion or Belief Regulations. In rejecting
the Council's argument, the EAT held that the
However, the Court of Appeal thoughtresponsibilities of a pastoral care teacher
otherwise. Overturning the decision in Kraus,involved giving advice upon a large number of
the Court ruled that such a restrictiveissues, not simply the teachings of the Roman
interpretation would undermine the wholeCatholic Church (which could be delegated to
purpose of the whistleblowing legislation,another teacher). It followed that it was not
which is to encourage workers to come forwarda genuine requirement for the post holder to
on the basis of their reasonable beliefs -be of Roman Catholic faith and the Council
not their legal expertise. Mr Babulahad  unlawful discriminated against Mr McNab.
therefore  won  his  appeal.
Finally, in New Testament Church of God v
Breaking  the  Chain  of  CausationStewart, the EAT has confirmed that a
minister of religion can bring a claim for
In order to succeed in a claim under theunfair dismissal as they are employed under a
PIDA, a worker must prove causation i.e. thatcontract of employment. In rejecting the
the relevant detriment or dismissal was atraditional view that a cleric is merely "a
direct result of having made a protectedservant of God", the EAT held that: "if the
disclosure. The case of Bolton School v Evansrelationship between church and minister has
involved an information technology teachermany of the characteristics of a contract of
who was concerned about the security of theemployment in terms of rights and
School's new IT system. His initial concernsobligations, these cannot be ignored simply
were not addressed and so to demonstrate thebecause the duties are of a religious or
system's potential weaknesses, he hacked intopastoral nature.



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