Croker v Surrey County Council - Time limits for protected disclosure claims must be observed [2011] EAT

Claims of detriment suffered as a result of protected disclosures made under Section 47B of the Employment Rights Act ('ERA') 1996 have to be brought within the statutory time limit of three months.

Mr Croker worked for Surrey County Council ('SCC') as a firefighter under the Retained Duty System. In August 2003 he suffered a broken finger whilst on duty, and accordingly brought a personal injury claim at the Guildford County Court in 2006.

Apprised of certain information that came to light in the course of his personal injury claim, in July 2007 SCC commenced disciplinary investigations against Mr Croker relating to claims he made for wages, overtime and travel in the period between July and August 2003.

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