An employer has a duty to maintain mutual trust and confidence with his employees. Under common law, an employer must not, without reasonable and proper cause, behave in a manner calculated or likely to destroy, or seriously damage the relationship of trust and confidence with an employees. Lawrence Onyango Oduori vs. Kenya Commercial Bank [2014] eKLR. The claimant filed this Claim against his former Employer Kenya Commercial Bank. He claimed that he was summarily dismissed him without due procedure. He questioned the validity of the reason given in justifying dismissal, and the fairness of the procedure. In this case, the court stated further that, “The employment relationship is dynamic and based on mutual trust and confidence. Long passage of time works against the possibility that such trust and confidence can be rebuilt. http://kenyalaw.org/caselaw/cases/view/98288/