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Farr v Ryefell Ltd - Time limit for unfair dismissal claim must be considered before, and separately to, question of requisite continuous service [2009] EAT

Mr Farr was dismissed on 20 November 2007 and claimed unfair dismissal (as well as a number of other matters) at an employment tribunal. He presented his claim on 14th May 2008. Mr Farr had appealed to Ryefell against the dismissal, and raised other grievances, on 14 February 2008. He argued that, under Employment Act 2002 s.32 and the Dispute Resolution) Regulations 2004 Reg 15, this should have triggered an automatic extension of time to 6 months - hence making his ET claim in time. However the ET, apparently considering only the basic three month time limit, ruled that his claim was presented out of time, and it had been reasonably practicable to bring the claim in time. It therefore dismissed the claim. 

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