“…9] IRLR 469, QBD, Briscoe v Lubrizol Ltd [2002] EWCA Civ 508; [2002] IRLR 607, Jowitt v Pioneer Technology (UK) Ltd [2003] ICR 1120, CA; and Awan v ICTS UK Ltd [2019] IRLR 212, EAT. He summarised the effect of those cases as follows:-…”
“…There is a useful review of the PHI cases by Simler P sitting in the Employment Appeal Tribunal in Awan v ICTS UK Ltd [2019] IRLR 212. She said at [55]:-…”