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In a case where there story is at all factually complicated – and quite likely, even if it isn’t – the tribunal will want a chronology. That means a list of the most important things that happened, with dates, in the order in which they happened. A simple chronology may just be a list of dates and events. Often the order in which things happened is extremely important to what inferences the tribunal will draw. Take a chronology that goes like this:

4/1/13 C started work

21/7/13 C announces pregnancy

22/7/13 C’s line-manager emails her a list of complaints about her latest assignment

28/7/13 C dismissed because ‘your work’s not good enough’

It’s pretty clear what’s happened there.

But change the order so that the email complaining about C’s work is on 21/7/13 and she announces her pregnancy the following day, and everything looks completely different. It might even be suggested (especially if she’s made the announcement very early in her pregnancy) that she has made the announcement when she has in order to make deter her employer from dismissing her.

It’s not usually as clear-cut as that, but often in the course of drafting a chronology you find that you notice some sequence of events that doesn’t quite fit with what one party or the other is saying.

I have 4 specific pieces of advice about chronologies, apart from the general observation that they are useful – both as a way of getting the sequence of events clear in your own head, and as a way of making your story clear to the tribunal.

1. Use a spreadsheet

Using a spreadsheet makes life easier because it doesn’t matter what order you put the events in – you can sort it into date order automatically periodically as you go through. That saves a lot of fiddly insertion of extra lines in a table.

2. Include page numbers

Part of the reason that chronologies are so useful is that bundles often aren’t properly in chronological order; mostly by accident, but sometimes even by design. If you have a bundle that isn’t in chronological order, it can be difficult to find any particular document, even if you know its date or approximate date, unless you know its exact page number. So for each event in your chronology that is closely associated with a document (e.g. the disciplinary hearing and the notes of the disciplinary hearing) or even is a document (e.g. the dismissal letter), include the page reference.

3. Use a spreadsheet intelligently

The facts will often have a number of separate strands: a formal disciplinary or capability process; various OH reports and consultations with the Claimant’s GP or specialist; a grievance process. Your chronology may be clearer if you separate out these strands into different columns, so for example you might have a ‘formal process’ column for disciplinary/capability hearings, invitations to hearings etc; a ‘sickness absence’ column for periods of sick leave; a ‘medical/OH’ column for OH referalls and reports and similar material; and so on.

4. Include blank lines

When you come to finalise and print your chronology so as to give it to the tribunal, you might want to add a blank line under each event so that if the ET members think there are other significant events that your chronology doesn’t record, they have space to add them.

See Workbook1 for an example of how the beginning of a chronology done this way might look.


  1. Naomi

    Dear Douglas

    I’m afraid I’ve deleted your post: you’re very welcome to contribute these kinds of thoughts to either of the two ‘are ETs corrupt?’ posts, but it’s off-topic here.

    kind regards


    • Douglas

      I had a chronology very much upon the lines above, and it was very useful, it formed the basis of my statement.
      The respondents submitted several undated documents and were criticised by the Judge for doing so.
      However despite these conflicts the Tribunal preferred the respondents’ version of events that is their right or function apparently. I found that with cronic depression and anxeity where in ones mind minutes can last for hours and days can last for minutes, a simple note on a chronology is very useful indeed.

  2. AK

    The problem I have experienced is that chronologies like the above obviously show the problem. But, often solicitors / barristers create pretty exhaustive chronologies extending 2 sides of A4 from which it isn’t easily possible to pick issues. However, the ones of those type are more suited when the Judge wants to use the chronology as a reminder for himself / herself of what happened when rather than as a tool that will by itself give the answers.

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