In Marinello v City of Edinburgh Council the Inner House of the Court of Session has held that an interval of 17 months between incidents of harrassment at work did not automatically mean that there could not be a course of conduct for the purposes of protection under the Protection from Harassment Act 1997.

Further, it was vital for a court to look at the course of conduct as a whole, rather than assess each individual incident separately, each of which, on its own, may not be sufficient to be considered as an act of harassment.