procedure, loss of earnings for unpaid sick leave caused by bullying, loss of earnings caused by demotion, loss of earnings caused by stigma of association with a corrupt employer affecting many employees (as opposed to an incident of dishonesty), redundancy pay lost due to being terminated just before they would have qualified for two years' service, and loss of health insurance. Defences Successful defences have been: the employer discovers that the employee was in such serious breach, that he could have been summarily dismissed, the contract allowed dismissal without disciplinary procedure, as long as notice was given or paid in lieu. Relation to unfair dismissal A wrongful dismissal can be a fair or unfair dismissal, just as an unfair dismissal may or may not be a wrongful dismissal in terms of whether the correct notice was given. If the employee had two year's service he could claim unfair dismissal if there was something wrong with the decision to dismiss as opposed to the length of notice. If the wrongfulness was the lack of grounds then is it pretty certain to also be an unfair dismissal. The unfair dismissal claim would, if he is well advised, be in respect of the post-termination period and sue in court for wrongful dismissal in respect of the notice period, thus stretching out the statutory limits by making the unfair dismissal limit only start running from a later date to allow perhaps more loss of earnings and ignoring the breach of contract limit by using the court instead of tribunal to deal with wrongful dismissal. The burden of proving double recovery is on the employer and tribunal awards for unfair dismissal can be vague as to what and when they are for. Relation to constructive dismissal A wrongful dismissal can be actual or constructive, but a constructive dismissal is almost certain to be a wrongful one, since the correct notice will not have been given if the dismissal was caused by a resignation, itself caused by the employer's serious breach of contract. An employee who was constructively dismissed, as well as possibly having a claim for breach of the duty not to destroy the bond of mutual trust, will usually have a claim for wrongful dismissal. As only economic loss can be claimed for breach of contract, the main loss will be earnings due to the lost notice period, as opposed to any disgruntlement about