Following the decision in Ramphal, a further EAT ruling has reiterated the importance of confining HR's role in disciplinary proceedings to one of advice on legal questions and process, and of ensuring that the conclusions in any investigatory report include all the conclusions of the person investigating the allegations and no-one else's view.

In Dronsfield v University of Reading the EAT was critical of the fact that significant opinions favourable to the claimant were removed from the draft investigation report at a late stage, following review by the HR department and in-house lawyer. The tribunal should have sought an explanation for the changes in order to be able to assess the fairness of dismissal based on the report, so the case was remitted for reconsideration.