Employment Appeal Tribunal Dismisses Whistleblowing Claim Against Greater Manchester Police
The Employment Appeal Tribunal has rejected a former senior police officer's appeal, ruling that no protected disclosures were established in the case against Greater Manchester Police.
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Tribunal Upholds Decision in Complex Whistleblowing Case
The Employment Appeal Tribunal (EAT) has dismissed an appeal brought by a former senior police officer, Mr Peter Jackson, who sought to challenge the rejection of his claims for whistleblowing detriment and constructive automatic unfair dismissal. The judgment, delivered by The Honourable Mr Justice Mansfield, brings an end to a protracted legal battle involving Greater Manchester Police.
Background to the Appeal
The Claimant, who served as a police officer for many years, had alleged that he made 19 protected disclosures to the Independent Police Complaints Commission (IPCC) in three lengthy reports. He further claimed that he was subjected to detriments, leading to his constructive resignation. The original Employment Tribunal, following a 102-day hearing, found that none of the allegations amounted to protected disclosures and that the Claimant was not constructively dismissed.
EAT Findings on Protected Disclosures
On appeal, the EAT addressed several grounds, including whether the original Tribunal erred in its approach to identifying the information disclosed. The EAT ruled that the Tribunal was entitled to consider the context and the totality of the reports submitted to the prescribed person, rather than being confined solely to the specific passages identified in the agreed List of Issues.
Furthermore, the EAT upheld the Tribunal's qualitative assessment regarding section 43F of the Employment Rights Act 1996. The judgment confirmed that the Tribunal did not apply an erroneous 95 per cent truth test. Instead, it correctly evaluated whether the Claimant held a reasonable belief in the substantial truth of the allegations made.
Constructive Dismissal Claims
As the Appellant failed to establish that any protected disclosures had been made, the grounds concerning constructive dismissal were deemed academic. Nevertheless, the EAT noted that the original Tribunal made no error of law in its findings that the Claimant did not resign in response to a repudiatory breach and had, in any event, affirmed the contract.
The EAT concluded that the Claimant's appeal failed on all grounds, including those relating to procedural fairness, credibility findings, and the interpretation of statutory provisions.
Read the entire judgment here: Jackson v The Chief Constable of Greater Manchester Police [2026] EAT 112
