For the latest information, see Bulletin 550. The reference above to the reason or principal reason for dismissal means the employer's reason. Normally, this does not cause problems, even in the case of a corporate employer, because the tribunal will simply look at the reason relied on by the dismissing manager, who for these purposes is taken to represent the employer. If he or she acted on the basis of the protected disclosure, the corporate employer will be liable. However, a possible complication may arise here (generally, but perhaps of particular concern in a whistleblowing case), if that dismissing manager has been manipulated and misled by a fellow manager who is the one who really objected to the disclosure and has engineered a false (non-disclosure) case against the employee in order to have him or her dismissed (referred to by Underhill LJ as an