Mr R Murphy v Scottish Courts and Tribunals Service: 8002002/2025

The Court of Appeal has cautioned tribunals against applying the concepts of 30 'policy, rule, practice, scheme or regime' too literally, particularly in the context of an alleged continuing act consisting of numerous incidents occurring over a lengthy period ( Hendricks v Metropolitan Police Commissioner, [2003] IRLR 96). Only acts of discrimination can fall within conduct extending over a period for this purpose – South West 35 Ambulance Service NHS Foundation Trust v King [2020] IRLR 168.