In Attorney General v Messi [2026] EAT 34, the EAT granted an indefinite Restriction of Proceedings Order (RPO) under section 33 of the Employment Tribunals Act 1996 against an individual (“C”) who had brought over 50 unsuccessful employment tribunal claims since 2017, many alleging discrimination, unpaid wages, and whistleblowing. None succeeded. The EAT held that C had habitually and persistently instituted vexatious proceedings without reasonable grounds. The order requires C to obtain permission from the EAT before bringing or continuing tribunal proceedings, although the Tribunal declined to restrict C from acting as a McKenzie friend or representative, finding it lacked jurisdiction to impose such a restriction.
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