option but to dismiss him. His appeal was dismissed. The Employment Appeal Tribunal considered the effect of the Dobie ruling but stated that Dobie Bancroft v Interserve (Facilities Management) Ltd., 13 December 2012: Interserve provided a catering service in a bail hostel operated by Lincolnshire Probation Trust. Dobie and Henderson were referred to in this case as the correct basis on which an Employment Tribunal should direct itself when considering whether an employer has "taken all steps to mitigate the injustice caused to a [dismissed employee] removed at the behest of a third party". Procedural fairness In addition to having a valid substantive reason to dismiss an employee, for a dismissal to be legal, the employer should be able to show that the procedure followed to dismiss the employee was procedurally fair. The requirement for procedural fairness was introduced by the Lords in Polkey v AE Dayton Services Ltd. In 2002, the Employment Rights Act 1996 was amended to give a statutory basis to procedural fairness—following a public consultation, this was repealed in 2008 and the law reverted to Polkey. Warnings A classic error is not giving the employee warnings, disciplinary rules, details of the allegations, the right of appeal or to be accompanied at a dismissal hearing, alternative employment options before termination subject to the group's size, or the chance to improve. Large employers will be expected to be professional. A re-hearing can rectify an unfair dismissal. Statement of reasons The employee is entitled to receive within 14 days a written statement of reasons for dismissal. The employer can comply by saying anything it believes. A missing, inadequate or untrue statement is itself grounds for a complaint to tribunal. The tribunal can then make its mind up as to the reason for dismissal and will award two weeks' pay for this procedural breach. The employee can use the statement to block the employer from changing the reason in its defence to a claim or to attack its credibility if there is such a change. Investigations Investigations must result in notes being kept and given to the employee. They cannot just consist of uncorroborated anonymous informants; sometimes the employee will be entitled to know his accusers and the accusations, although the employee is not entitled to know everything as long as he knows the accusation. Anonymous accusers are easy to attack anyway as there may be questions around grudges, ability