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But if the employer is not justified in making a summary dismissal, the employee has a claim under ERA section 13 for a shortfall in wages. The same principle, that a serious breach of contract gives the other side the option to terminate, [] also works in favour of employees.

In Wilson v Racher [] a gardener was bullied by his employer, the heir of Tolethorpe Halland gave him a rude telling off for not picking up some string on the lawn.

Mr Wilson, the gardener, told Mr Racher ""get stuffed, go and shit yourself"". The Court of Appeal held that the employer's attitude meant this breakdown in trust and confidence was the employer's own doing, and because the law no longer saw employment as a "" Czar - serf "" relationship, Mr Wilson was in the right and was wrongfully dismissed.

The remedy for breach of contract, following a long tradition that specific performance should not result in draconian consequences or binding hostile parties to continue working together, [] is typically monetary compensation to put the claimant in the same position as if the contract had been properly performed.

However, in Edwards v Chesterfield Royal Hospital[] the Supreme Court held that an injunction is available to restrain breach of contract for the employer's failure to follow a doctor's contractual disciplinary procedure. This indicated that specific performance should always in principle be available, particularly in large organisations where people can be shifted to avoid personality conflicts.

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