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Obonyo v Wandsworth Primary Care Trust - Tribunal has power to clarify and, in cases of fraud or mistake, set aside consent order on review [2007] EAT

Mrs Obonyo won a claim for unfair dismissal and race discrimination and was awarded £104,000. Wandsworth's appeal was allowed and the case went back to a new tribunal. During that (second) hearing the parties reached a settlement. Their agreement was recorded in a consent order and the case dismissed on withdrawal.

A dispute arose over whether the sum agreed was net, or a gross figure from which tax needed to be deducted. The employment judge refused an application for review, saying that the tribunal had no power to change a consent order. Mrs Obonyo appealed.

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