In practice, it is exceptionally difficult to bring a case based on the PHA 97 as a response to workplace bullying. To amount to harassment under the PHA 97, conduct must cross the boundary between being “unattractive and even unreasonable” and become “oppressive and unacceptable” (Sunderland City Council v Conn [2008] IRLR 324) and “of an order which would sustain criminal liability” (Veakins v Kier Islington Ltd [2010] IRLR 132).