However, there is no absolute rule that an employer warn an employee before summarily dismissing him or her for just cause. In Leach v. Canadian Blood Services, [2001] 5 W.W.R. 668 at ¶ 177, 7 C.C.E.L. (3d) 205, 2001 ABQB 54, Coutu J. stated: Whether a warning and an opportunity to improve is necessary to justify summary dismissal depends upon the circumstances and the nature of the misconduct. The greater the wrong, the less likely it is that an employer will be required to first put the employee on notice that such misconduct is not acceptable to the employer….
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