Watson v University of Strathclyde - Apparent bias and the implied term of trust and confidence  EAT
Sally Watson, a publications officer in the University of Strathclyde Marketing and Communications office, resigned and claimed constructive unfair dismissal. The EAT has ruled in her favour, overturning a decision of a Glasgow employment tribunal, on the basis that inclusion of a particular individual on a panel to hear a complaint she had brought indicated apparent bias and a breach of the implied term of trust and confidence.
She had raised a complaint about the behaviour of the head of her department, a Mr Taylor. Her complaint was considered (and dismissed) by a 3 person panel which, in spite of her objections, included a Dr West. He was a senior member of the University staff, "a powerful figure" who was one of those who had been responsible for appointing Mr Taylor to his post and who had supported Mr Taylor in some recent problems he had had with the police.