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Meares v Medway Primary Care Trust - Whistle-blowing, "good faith" and ulterior motives [2010] EAT

To amount to a "protected disclosure" certain statutory requirements must be met, including that (when made to an employer) the disclosure be made "in good faith". A tribunal is not required, where motives may be mixed, to evaluate those motives and ascertain a "predominant" one: it is entitled, if it believes that the motive was, for example, personal antagonism, to rule that the disclosure was not made in good faith.  

Nurse Miss Meares worked for Medway between 1997 and 2008. From 2005 she went off on long-term sick absence until March 2007. Her line manager, a Mrs Cable, wrote to her in May 2007 about the fact that she was reportedly arriving late for the work-shadowing duties she undertook as part of a phased return. Miss Meares wrote a "vehement letter" in response, and ultimately resigned.

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