Kilraine v London Borough of Wandsworth (UK, 2018)

Court of Appeal (England and Wales) case on what an employment tribunal needs to consider when determining what constitutes a disclosure of information for the purposes for the Public Interest Disclosure Act 1998 (PIDA). The appellant, Ms Kilraine, claimed she was dismissed by her employer because she had raised concerns internally about having been bullied and harassed, and about a safeguarding incident, both of which she alleged had not been adequately addressed. The Court of Appeal analysed the distinction between ‘allegations’ and ‘information’ opining that the two were not mutually exclusive before concluding that the appellant’s disclosures were mere allegations and did not amount to a ‘disclosure of information’ for the purposes of PIDA. The Court went on to stress that a disclosure must contain sufficient factual content and specificity for it to qualify as ‘information’ under the law.