In Adey Jones v O’Dowd, Mrs O’Dowd was dismissed following an investigation into theft from a care home run by Mrs Adey Jones. Mrs O’Dowd commenced work elsewhere but following illness resigned from her job. She successfully claimed unfair dismissal and the tribunal, considering compensation, awarded her a sum to cover her losses during the period she was unable to work because of sickness. The EAT allowed Mrs Adey Jones’s appeal, noting that Mrs O’Dowd’s illness started 20 weeks after dismissal and there had been other potential contributory factors such as police and council investigations. Future losses should not be determined on an ‘all or nothing’ causation approach but by assessing the percentage likelihood that the underlying condition might have prevented Mrs O’Dowd from working in any event.