In Yorkshire Housing v Swanson the EAT held that an employer who had delayed for five months between holding the disciplinary meeting and dismissing Mrs Swanson had automatically unfairly dismissed her. Mrs Swanson had been employed for 13 years as a local government officer. In the course of a friendship with Mr Azam she introduced him to the company when he sought the tenancy of a property belonging to it. She also assisted him in completing forms which claimed he was in receipt of social security benefit. She was suspended on suspicion of assisting Mr Azam to obtain a tenancy when she must have known he was not in receipt of state benefits. A disciplinary meeting was held on 17 February 2005 and some 5 months later on 14 July Mrs Swanson was dismissed for gross misconduct. The EAT highlighted that the Dispute Resolution Regulations 2004 contain a general requirement that each step and action must be taken without unreasonable delay. The EAT accepted that an employer might in some cases be able to argue that it was ‘not practicable’ to comply but this was not the case here. It stated that ‘delay is always the enemy of fair dispute resolution’. With this in mind, employers should ensure that their disciplinary procedures are followed without unreasonable delay. This general requirement is unlikely to be affected when the statutory disciplinary and grievance procedures are scrapped in April 2009 since this is a fundamental requirement to ensure fairness.