In this update: Samuel Smith Old Brewery (Tadcaster) v Mr Marshall & Mrs Marshall – Failure to hold a grievance appeal before the conclusion of disciplinary proceedings did not render a dismissal unfair. BP plc v Elstone and another – A worker can bring a whistleblowing claim against a current employer based on a protected disclosure made while working for a previous employer. Malone and others v British Airways Plc – A collective agreement concerning crewing levels is found not to be incorporated into employees’ contracts. Chief Constable of South Yorkshire v Mr M D Jelic – Reasonable adjustments under the Disability Discrimination Act 1995 can include swapping a disabled employee’s role with a non-disabled employee’s role. Equality Act 2010. Additional Paternity Leave and Pay Regulations. Fit notes replace sick notes – Medical statements will now include GP’s advice on the adjustments necessary to enable a recovering employee to return to work.