In Gibbs t/a Jarlands Financial Services v Harris EAT/0023/07 the Employment Appeal Tribunal held that an employee whose complaint of unfair constructive dismissal was rejected by a tribunal because he had failed to comply with step one of the statutory grievance procedure could not, when resubmitting his claim, rely on the ET1 that he had completed in relation to the original claim as constituting his written statement of grievance
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