In R (on the application of Kirk) v Middlesbrough Council and another  IRLR 699 HC, the High Court held that a social worker accused of withholding information about a child protection investigation, of which she was the subject, from her private sector employer was not entitled to legal representation at a disciplinary hearing.
The High Court has held that an individual was not entitled to legal representation at internal disciplinary proceedings, on the basis that it was a private law employment case on a standalone disciplinary issue.
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