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Dutch Supreme Court: whistleblower

On February 7, 2025, the Dutch Supreme Court issued its first ruling on the Whistleblower Protection Act (Wbk). The ruling focuses on the presumption of evidence regarding the prohibition of disadvantage in the Wbk. The Supreme Court clarifies that, to rebut this presumption of evidence, the employer cannot merely rebut the causal relationship between the report and the disadvantage but must prove the opposite.

The Whistleblower Protection Act

The Wbk implements Directive (EU) 2019/1937 (“the Whistleblower Directive”) and aims to provide more protection to employees who report (suspected) wrongdoing in the workplace. Our other blog about the Wbk provides further explanation of the law.

The prohibition of disadvantage is included in Article 17e of the Wbk. This article states that a person who reports or discloses suspected wrongdoing – a whistleblower – must not suffer any disadvantage from this. When the whistleblower nevertheless experiences adverse consequences after making a report or disclosure, it is presumed that this disadvantage is the result of the report, as stated in Article 17eb of the Wbk.

It is then up to the employer to rebut this presumption. However, it was unclear how the employer should do this. Is it sufficient to merely rebut the presumption, or must the employer prove that the disadvantage is not a result of the report? The Supreme Court clarifies this in this ruling.

Background of the case

The case involved a dispute between an employee, the appellant in cassation, and the employer, the Omgevingsdienst IJsselland. The Omgevingsdienst wanted to terminate the employee’s employment agreement and went to the subdistrict court. However, the employee had previously reported suspected wrongdoing at the Omgevingsdienst, which would make the prohibition of disadvantage applicable. According to the subdistrict court, the termination request related to facts and circumstances that had occurred before the wrongdoing report, meaning the prohibition of disadvantage did not apply. Therefore, the employment agreement could be terminated by the subdistrict court.

The Court of Appeal ruled similarly, after which the employee appealed to the Supreme Court. The employee complained that the Court of Appeal failed to recognize that the Omgevingsdienst could not suffice with merely rebutting the presumption of evidence that there was a connection between the report and the termination request, and that the Omgevingsdienst should have provided proof of the contrary.

Supreme Court’s Ruling

The Supreme Court rejects this complaint. The Supreme Court considers in paragraph 4.4 that multiple passages in the legislative history of Article 17eb Wbk indicate that the legislator intended for the employer to prove that the disadvantage is not a result of the report, and that it is therefore up to them to prove that the disadvantage occurred on grounds other than the report. According to the Supreme Court, the rule of evidence laid down in Article 17eb Wbk must therefore be understood to mean that the employer cannot suffice with merely rebutting the presumption of a causal relationship between the report and the measure to counter the statutory presumption of evidence, but must prove the opposite. The fact that the term ‘ontzenuwen‘ (rebut) was used in this context in the legislative history of Article 17eb Wbk does not affect this, according to the Supreme Court.

Unfortunately for this employee, the appeal is rejected. According to the Supreme Court, the complaint was based on an incorrect reading of the contested ruling. The employee’s complaint stated that the Omgevingsdienst should have provided proof of the contrary. The Supreme Court explains that the Court of Appeal’s ruling means that the Omgevingsdienst did not merely rebut the presumption that there was a causal relationship between the report and the termination request but proved the opposite. And this is exactly what the Omgevingsdienst, according to the complaint, should have done.

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Dutch Supreme Court:  whistleblower