EAT on 16th June 2009, reported at [2009] ICR 1538
Representation:
a decision to extend a probationary period counted as relevant disciplinary action for the purposes of the grievance procedure rules in force from October 2004 until April 2009 and thereafter in transitional cases (under those rules an employees who wished to bring a grievance after being subjected to disciplinary action by the employer had to use different grievance procedures depending on whether or not the disciplinary action was "relevant" disciplinary action within the definition set out in regulations ).
For relevant general notes see Definitions and interpretation/relevant disciplinary action and/or Grievance procedures/2004 rules and/or Disciplinary and Grievance Procedures - 2009 changes/transitional provisions .