In Stevens v University of Birmingham, the High Court has held that on the facts it would breach the contractual duty of mutual trust and confidence for the claimant not to be allowed to be accompanied by a member of a medical defence organisation (not a colleague or union representative) in an investigatory meeting. See Grievance and disciplinary procedures>Right to be accompanied.

Along with the Leeds Dental Team case, this is another example of the courts indicating that the duty of trust and confidence may expand the range of people an employee may insist accompanies him, if the argument to allow a particular person is strong enough.

This may apply to an employee with a health condition even if they do not have a disability, and so no right to reasonable adjustments under the Equality Act.