Has the horse bolted before the stable door is shut?

Sec 387 of the Fair Work Act provides that in determining whether an employee has been dismissed in a relevantly unfair manner, one of the issues to be taken into account is whether the employee was notified of the reason. Sub-sec 387(b). The sub-section does not say whether the issue is whether that notice was provided before the employer makes the decision but the question was addressed in explicit terms in Chubb Security Australia Pty Ltd v Thomas Print S2679, also in Crozier v Palazzo Corporation Pty Ltd (2000) 98 IR 137, 151, and in plain and clear terms, Previsic v Australian Quarantine Inspection Services Print Q3730. In Crozier v Palazzo Corporation Pty Ltd (2000) 98 IR 137 a Full Bench of the Australian Industrial Relations Commission dealing with a similar provision of the Workplace Relations Act 1996 stated the following:
“As a matter of logic procedural fairness would require that an employee be notified of a valid reason for their termination before any decision is taken to terminate their employment in order to provide them with an opportunity to respond to the reason identified. Section 170(3)(b) and (c) would have very little (if any) practical effect if it was sufficient to notify employees and give them an opportunity to respond after a decision had been taken to terminate their employment. Much like shutting the stable door after the horse has bolted.”
Tran v Parmalat Food Products Pty Ltd (2015) FWC 5535 27 August 2015 per Lawrence DP