2401089/2024

Chorlton Family Practice (“CFP”) and Others

v Dr C Colaco

22 May 2026·Employment Tribunal·England & Wales·Employment Judge McDonald

Respondent

Chorlton Family Practice (“CFP”) and Others

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Decision date

22 May 2026

Tribunal

Employment Tribunal

Jurisdiction

England & Wales

Judge

Employment Judge McDonald

Case Summary

Dr Caroline Colaco, a locum GP at Chorlton Family Practice in Manchester, claimed she was subjected to detriments for making protected disclosures about concerns regarding another doctor's practice. The respondents conceded the disclosures were protected but disputed causation. The tribunal found all claims not well-founded, as the claimant failed to establish that the alleged detriments were because of her protected disclosures.

Why this outcome?

Claim not well-founded

The tribunal found that although the claimant made protected disclosures and the respondents conceded this, the claimant failed to establish the necessary causal connection between the protected disclosures and the alleged detriments. The respondents demonstrated that decisions about work allocation and termination of the locum engagement were made for legitimate business reasons unrelated to the whistleblowing, particularly the recruitment of salaried GPs and changed funding priorities.

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Key Issues

  • Whether claimant made protected disclosures
  • Whether claimant subjected to detriments for making protected disclosures
  • Whether claimant had worker status under s.230 ERA 1996
  • Time limits and jurisdiction
  • Causal connection between disclosures and alleged detriments

Decision Text

Full PDF

1 EMPLOYMENT TRIBUNALS Claimant: Dr Caroline Colaco Respondent: R1 Chorlton Family Practice (“CFP”) The trading name of the following individual respondents R2 Dr Karim Fawzi Adab R3 Dr Helena Mulkeen R4 Professor Carolyn Anne Chew-Graham R5 Dr Louise Miriam Freedman R6 Dr Veselin Kirilov Cahvdarov R7 Dr Duncan Rutherford Hill R8 Dr Volker Walter Martin Siebert R9 Dr Megan Elizabeth Atherton Heard at: Manchester (by hybrid remote and in person) On: 29 and 30 September, 1-6 and 9 October 2025 and 10 November 2025 (in chambers). Before: Employment Judge McDonald Mr A Egerton Ms B Hillon REPRESENTATION: Claimant: Mr B Williams (Counsel) Respondent: Miss A Smith (Counsel) RESERVED JUDGMENT The unanimous judgment of the Tribunal is that: 1. The complaints of unfair dismissal (“ordinary” unfair dismissal and “automatic” unfair dismissal under s.103A of the Employment Rights Act 1996) are dismissed on withdrawal. 2. The complaints of being subjected to detriments for making protected disclosures at 8(f)(h)(j) and (l) of the List of Issues are dismissed on withdrawal. 2 3. The claimant’s other complaints of being subjected to detriments for making protected disclosures are not well-founded and are dismissed. REASONS Introduction 1. This was the final hearing of the claimant’s claim against the respondents. The first respondent is a GP practice in Manchester. The second to ninth respondents were the partners in the practice at the relevant time. For convenience we refer to the practice as “CFP”. The claimant worked as a locum GP at CFP. 2. The hearing took place before a full Tribunal panel at Manchester Employment Tribunal. We converted the hearing from an in person to a hybrid hearing to enable 2 of the respondents’ witnesses to give evidence remotely by CVP video link. 3. It was agreed that the hearing would deal

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