“…ase-law that it is not possible straightforwardly to read across between the two legislative schemes: she referred to para. 33 of my judgment in Timis v Osipov [2018] EWCA Civ 2321, [2019] ICR 655 (p. 666 A-B), which quotes para. 48 of the judgment of Mummery LJ in Kuzel v Roche Products Ltd [2008] EWCA Civ 380, [2008] ICR 799 (p. 809 D-E…”
“…riment, achieved by way of the Enterprise and Regulatory Reform Act 2013 (“ERRA”) amending s.47B, the rationale was explained by Underhill LJ in Timis v Osipov [2018] EWCA Civ 2321, at [28] – [31]. In a nutshell, the protection for “protected disclosures” was only hitherto available in respect of acts or omissions by the employer. There h…”