Glasgow Life

Case Summary

The claimant sought to amend his claim to add a new complaint of automatic unfair dismissal under section 103A ERA based on alleged protected disclosures. The tribunal refused the amendment application, finding that the new complaint was made significantly out of time (17 March 2026, over two years after dismissal on 4 July 2024), and that it was not reasonably practicable for it to have been omitted from the original ET1 submitted on 13 January 2025, particularly given the claimant had professional legal representation at that time.

The tribunal refused the amendment because the complaint of automatic unfair dismissal under section 103A ERA based on protected disclosures was submitted significantly out of time (17 March 2026, nearly two years after dismissal and over two months after the extended limitation period closed on 13 January 2025). The tribunal found it was not reasonably practicable for this distinct complaint to have been omitted from the original ET1, since the claimant had professional legal representation at that time and had already brought a standard unfair dismissal complaint within the time limit. The section 103A claim constitutes a separate and distinct complaint from the section 98 unfair dismissal claim originally pleaded.

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• •Whether claimant's application to amend ET1 to add claim of automatic unfair dismissal under section 103A Employment Rights Act 1996 based on protected disclosure (whistleblowing) should be allowed
• •Whether amendment was made out of time and whether it was reasonably practicable for the complaint to have been submitted within the statutory time limit
• •Distinction between unfair dismissal under section 98 ERA and automatic unfair dismissal under section 103A ERA

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