10 November 2011
Nolan v Balfour Beatty Engineering Services UKEAT/0109/11/SM, [2011] All ER (D) 09 (Nov)
When deciding what would have been a reasonable time within which to present a late claim, employment tribunals were required to bear in mind the context, namely a primary time limit of three months and the general principle that litigation should be progressed efficiently and without delay. They were then required to consider all the circumstances of the particular case, an exercise which would inevitably include taking account of what the claimant did and what he knew about time limits, what he, reasonably, ought to have known about them, and they were required to ask themselves why it was that the further delay had occurred.
