Time limits may be extended following wrong information from an employer (but not an adviser)

Northamptonshire County Council v Entwhistle [2010] UKEAT/0540/09/ZT

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29/06/2010

  • Time limits run three months from the effective date of termination (not the appeal).
  • Wrong information from an employer might lead to an extension
  • Wrong information from your solicitor will not.
  • The remedy for a lawyer's wrong advice is make a claim for negligence against him

Underhill P's EAT decision in Northamptonshire County Council v Entwhistle has reconfirmed that where it remains reasonably practicable for an employee to file his unfair dismissal claim within the time limits (three months from the effective date of termination) there will be no time extension allowed.

Where an employer has misled the employee the tribunal will normally take this into account when deciding whether to extend the time limit.

In this case however, where the employer did mistakenly advise the claimant that the time limit for claiming unfair dismissal ran from the date of the rejection of their appeal, no extension was granted. This is because the claimant's solicitor had confired the employer's mistaken advice. Where this happens relevant case law applies (Dedman v British Building and Engineering Appliances Ltd [1974] ICR 53 and Marks & Spencer PLC v Williams-Ryan [2008] ICR 193). This states that the employee's only remedy is to claim damages in negligence from his solicitor who is expected to know the correct time limits and file a client's claim in time.

The transcript of this case follows:-  

Northamptonshire County Council v Entwhistle [2010] UKEAT/0540/09/ZT


Abroad      Agency      Appeals (ET)      Closed_Procedure      Compensation      Constuctive_Dismissal      Contract      Costs      Discrimination      Age Discrimination      Disability Discrimination      Race Discrimination      Religious Discrimination      Sex Discrimination      Sexual Orientation Discrimination      Discipline      Dispute_Resolution      Employer_Liability      Employment Status      Equal Pay      Harassment and Bullying At Work      Tribunal Hearing      Holidays and Holiday Pay      Employer Negotiations      Part-Time      Pay      Pensions      Palestine      Employment Tribunal Procedure      Restricted_Reporting_Orders      Sanctions      Sickness      Tribunal Settlement and Compromise Agreements      Time_Limits      Tupe      Unfair and Wrongful Dismissal      Union      Victimisation      Whistleblowing     


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If you have a problem at work over harassment, disability, sex, age, race discrimination or bullying or are seeking compensation or reinstatement for unfair or constructive dismissal then contact workrep for an evaluation of your case. We can also advise you on equal pay, TUPE or employment status. Often an employee will come to us over a breach of contract by their employer or for issues concerning whistleblowing. If your employer has made you redundant you might in fact have been unfairly dismissed or wrongfully dismissed. If you have any other employment issues don't hesitate to contact WorkRep.
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