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Sheffield City Council v Dolby - Failure to abide by statutory grievance requirements [2011] EAT

Raising a protected disclosure matter at the stage of an internal appeal after two grievances had already been considered was too late in the process for it to amount to a step one grievance under the now-repealed statutory grievance provisions.

Ms Dolby worked as an Education Welfare Officer for Sheffield City Council. in May 2006 she made a referral concerning the welfare of a child. 18 months later she raised a complaint about bullying and harassment by 4 colleagues as a result, having gone off sick. In March 2008, that complaint having apparently been dismissed, Ms Dolby lodged a formal grievance about how that complaint had been handled. The grievance was dismissed but in her appeal Ms Dolby raised having been subjected to detriment as a result of having made protected disclosures - something accepted on its face as a "qualifying protected disclosure".

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