Follow us

Employers should ensure managers holding or attending disciplinary or grievance hearings with an employee are aware of the risk of making inappropriate comments whether publicly in the hearing or privately during breaks, given the possibility of comments being covertly recorded by the employee on mobiles or other devices and admitted in evidence by a tribunal.

In Punjab National Bank v Gosain, the EAT upheld a tribunal decision admitting in evidence covert recordings of private comments made by members of a disciplinary and grievance panel during a break in the proceedings. The comments were not a part of the panel's deliberations in relation to the matters under consideration and therefore were not inadmissible. 

Although it would not prevent the tribunal exercising its discretion to admit covert recordings in evidence, it is prudent for employers to expressly prohibit the recording of proceedings without consent in their disciplinary and grievance policies; at the very least it may discourage such conduct.

Key contacts

Samantha Brown photo

Samantha Brown

Managing Partner of EPI (West), London

Samantha Brown
Steve Bell photo

Steve Bell

Managing Partner - Employment, Industrial Relations and Safety (Australia, Asia), Melbourne

Steve Bell
Emma Rohsler photo

Emma Rohsler

Regional Head of Practice (EMEA) - Employment Pensions and Incentives, Paris

Emma Rohsler
Andrew Taggart photo

Andrew Taggart

Partner, London

Andrew Taggart
Fatim Jumabhoy photo

Fatim Jumabhoy

Managing Partner, Singapore, Singapore

Fatim Jumabhoy
Barbara Roth photo

Barbara Roth

Partner, New York

Barbara Roth