1. an unauthorised or "clandestine" electronic recording made by an employee at a disciplinary panel hearing and subsequent appeal can be used as evidence in an Employment Tribunal hearing for unfair dismissal, provided of course it is relevant to the issue between the parties, except to the extent that it is a recording of the private deliberations of the panel;
   
2. failure to maintain respect for the privacy of private deliberations would be contrary to the public interest as it would inhibit panel members from entering into open discussion and could give rise to satellite litigation based on leaks of the recordings.

For relevant general notes see Procedure of Employment Tribunals/admissibility of evidence and see also Bills before Parliament/Interception of Communications (Admissibility of Evidence) Bill .