St John Ambulance v Mulvie - claim was out of time from last act complained of, so "continuing act" question was irrelevant

When determining whether a whistle-blowing (or, indeed, other discrimination) claim has been presented within the three month time limit, a tribunal should first determine whether any detrimental conduct occurred within three months of the date of the presentation of the claim. If not, then the claim will be out of time, and it is irrelevant whether the last act complained of forms part of a "continuing act" with earlier incidents. 

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