pay for it, e.g. using a salary review. Dismissal at the request of a third party Several cases within the jurisdiction of the Employment Appeal Tribunal and elsewhere have looked at the lawfulness of dismissals "at the behest of a third party" such as a major customer of the employer. Selected Cases: Scott Packing & Warehousing Co Ltd. v Paterson, 1978, IRLR 166, established that third party pressure to dismiss could constitute "a substantial reason" for a fair dismissal. Under the Employment Rights Act 1996 and preceding statutes, "some other substantial reason" may be sufficient to render a dismissal "fair". Dobie v Burns International Security Services (UK) Ltd: Court of Appeal, 14 May 1984. Dobie worked as a security officer for Burns International Security Services, who provided security at Liverpool Airport, which was at that time operated by Merseyside County Council. The Council had the right of approval of any employee of the company at the airport. There was a complaint about Mr Dobie and as a result the council asked for him to be removed from airport employment. Dobie moved him to a lower-paid position elsewhere in the area, an action which is treated in English law as a dismissal. An Industrial Tribunal (IT, now known as an Employment Tribunal) held that there was a substantial reason justifying dismissal, and by a majority the Employment Appeal Tribunal upheld this decision. However, the Court of Appeal disagreed, stating that in deciding whether Burns had acted reasonably, the tribunal needed to consider whether an injustice had been done to the complainant. The IT had failed to consider this and the Court of Appeal referred the matter back to the Industrial Tribunal. Henderson v Connect (South Tyneside) Ltd., 8 September 2009: an employee responsible for driving a school bus was dismissed by his employer at the insistence of a local authority, South Tyneside Council. Allegations of sexual abuse had been made which the appellant denied and for which the police had declined to prosecute. The South Tyneside Safeguarding Children Board had reviewed the case, and its conclusion was that Mr Henderson could no longer work with children. Under the terms of the contract between the Council and the employer, the Council had an absolute right to veto the employment of particular individuals in providing the service. As there were no other roles he could undertake, the employer decided there was no other