An employee working as a cleaner in a building used both as the employer's office and the managing director's home was unfairly dismissed when the managing director's husband, who was also a consultant to the employer, shouted at her while giving her cleaning instructions. Although based on unusual facts, the case does highlight that in certain situations employers can be liable for the acts of third parties. The employer could be vicariously liable for the wrongdoer's acts where the wrongdoer was impliedly authorised to do what he did, albeit in an unauthorised manner; alternatively, the employer may be liable for breach of the duty to provide a reasonably suitable working environment so far as reasonably practicable (ie, for knowing about the treatment and failing to take steps to stop it). (De Clare Johnson v MYA Consulting Ltd, EAT)