Where a claim of bullying is made, can an employee refer back to incidents that took place several years ago?

According to the Labour Relations Commission’s Procedures for Addressing Bullying in the Workplace, workplace bullying is defined as:  “repeated inappropriate behaviour, direct or indirect, whether verbal, physical or otherwise, conducted by one or more persons against another or others, at the place of work and/or in the course of employment, which could reasonably be regarded as undermining the individual’s right to dignity at work. An isolated incident of the behaviour described in this definition may be an affront to dignity at work but, as a once off incident, is not considered to be bullying”.

The Irish Courts have held that, implicit in the requirement that the inappropriate