In the high profile judicial review case of R (on the application of Sharon Shoesmith) v OFSTED and others, the process under which the former Director of Children's Services for Haringey was removed from office and summarily dismissed came under scrutiny. The Court of Appeal held that the decision to dismiss was unlawful and void. Although the outcome of the case ultimately turned on specific statutory provisions, the Court's comments relating to procedural fairness are of general relevance. Lord Justice Maurice Kay commented that "accountability" is not synonymous with "heads must roll". Accountability requires that the accountable person is obliged to explain and there must be an opportunity to do so. If the explanation is unacceptable, then consequences would follow for the employee. Despite the urgency of the situation in this case, allowing her to answer the charge would have entailed only a modest delay.