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Case law
Shergold v Fieldway Medical Centre

A written complaint can count as a grievance even without the right wording

The ruling

“A written complaint counts as a grievance if its substance is clear, even with no set format or wording.”

A written complaint can count as a grievance even without formal wording or a full list of every incident.

  • Put your concerns in writing as soon as you can, even briefly, since this may protect your position later.
  • Do not assume an email or resignation letter does not count as a grievance just because you did not call it one.
  • A refusal to engage with your complaint is itself a sign that the situation needs a second, informed opinion, don't navigate that alone.
Read the full case

The situation

A practice manager at a medical centre resigned and later brought a claim for constructive unfair dismissal. Before resigning, she had put a complaint in writing about how a manager had treated her, but she had not labelled it as a formal grievance, and some of the incidents she later relied on in her tribunal claim were not spelled out in that letter. Her employer argued that she had not properly raised a grievance first, so her claim could not go ahead.

What the tribunal found

The Employment Appeal Tribunal disagreed with the employer's argument. It held that the requirements for a valid written grievance were minimal. All that mattered to the EAT was that the complaint was written down and covered the same ground as the later claim, the letter's label, its wording, and its level of detail were beside the point. A letter of resignation could itself count as a valid grievance letter. What mattered was that the complaint was in writing and that its substance matched the substance of the later claim. The EAT also found that once an employee has raised a grievance about an ongoing course of unreasonable treatment, they do not have to raise a fresh grievance every time something similar happens again.

Full citation

Shergold v Fieldway Medical Centre [2006] IRLR 76; [2005] UKEAT 0487_05_0512. Employment Appeal Tribunal. 2005.

Last reviewed 11 July 2026