* * *" Moreover, the cases interpreting section 24-12 prior to the amendment of its hearing provisions have held that the act must be complied with strictly and that tenured teachers may be dismissed only if the procedures of the section are followed. (See, e.g., Smith v. Board of Education (1977), 52 Ill. App.3d 647, 650; Gould v. Board of Education (1975), 32 Ill. App.3d 808, 811; Neal v. Board of Education (1977), 56 Ill. App.3d 10, 14.) The new amendment makes a hearing mandatory upon the board unless the discharged teacher waives the hearing.

We list a sampling of them. Cases in which just cause was found not to exist include Pickering v. Board of Education of Township High School District 205, 391 U.S. 563, 88 S.Ct. 1731, 20 L.Ed.2d 811 (1968) (teacher made public comments on school matters); Gould v. Board of Education of Ashley Community Consolidated School District Number 15, 32 Ill. App.3d 808, 336 N.E.2d 69 (1975) (teacher dozed off in a class she was attending as an observer); Wells v. Board of Education of Community Consolidated School District Number 64, 85 Ill. App.2d 312, 230 N.E.2d 6 (1967) (teacher of mentally handicapped children kept "unsophisticated" and incomplete journals of the activity of each pupil); Calhoun v. Cassady, 534 S.W.2d 806 (Ky. 1976) (teacher supported a superintendent's opponent in a school board election); Harris v. Mechanicville Central School District, 86 Misc.2d 144, 382 N.Y.S.2d 251 (1976), modified, 57 A.D.2d 231, 394 N.Y.S.2d 302 (1977), modified, 45 N.Y.2d 279, 408 N.Y.S.2d 384, 380 N.E.2d 213 (1978) (teacher left a private conference and refused to return despite the principal's order). The cases in which just cause has been found to exist are just as varied, sometimes on facts quite similar to those which other courts have found to be insufficient.

The incapacity must be in effect at the time action is taken by the Board of Education. The projected duration of the incapacity must be long term or indefinite with no reasonable prospect for rapid rehabilitation. This interpretation of physical incapacity is consistent with the interpretations of similar laws in other jurisdictions. E.g., Tilton v. Board of Education, 25 Cal.App.2d 746, 78 P.2d 474 (1938); Gould v. Board of Education, 32 Ill. App.? 808, 336 N.E.2d 69 (1975); Smith v. Board of Education, 293 N.W.2d 221 (Iowa, 1980). We believe this interpretation is consistent also with the purpose of the Act, as explained by Chief Justice Sharp, "to provide teachers of proven ability for the children of this State by protecting such teachers from dismissal for political, personal, arbitrary or discriminatory reasons."

Despite this language, the Board contends that there is no duty to hold a hearing prior to the end of the school term and argues that both our earlier decision in this case and Neal v. Board of Education (1978), 56 Ill. App.3d 10, 371 N.E.2d 869, should be reversed. • 1 In the first appeal in this case, we held that the Board had lost jurisdiction to dismiss petitioner by failing to hold a dismissal hearing. Under the School Code, a tenured teacher may be dismissed for cause, but such dismissal can be accomplished only by following the procedures prescribed by section 24-12 ( Gould v. Board of Education (1975), 32 Ill. App.3d 808, 336 N.E.2d 69, 72; Miller v. Board of Education (1964), 51 Ill. App.2d 20, 200 N.E.2d 838, 842). The Act is essentially procedural and thus must be strictly complied with in dismissing a tenured teacher.

• 3 The teacher tenure act is essentially procedural. A teacher under contractual continued service can be dismissed for cause, but such dismissal can be validly accomplished only by adherence to the methods prescribed by section 24-12 of the School Code. ( Smith v. Board of Education, 52 Ill. App.3d 647, 367 N.E.2d 296; Gould v. Board of Education, 32 Ill. App.3d 808, 336 N.E.2d 69, 72.) Therefore, we find that the plaintiff was dismissed in a manner which violated the statutory time requirements for dismissal ordained by section 24-12, and that the dismissal is void. Because of our holding on this issue, it is unnecessary to consider the remaining assignment of error raised on this appeal.

Hankenson v. Board of Education, 10 Ill.2d 560, 563, 141 N.E.2d 5; Danahoo v. Board of Education, 413 Ill. 422, 425, 109 N.E.2d 787; Lusk v. Community Consolidated School District No. 95, 20 Ill. App.2d 252, 155 N.E.2d 650, 653; Graham v. Board of Education, 15 Ill. App.3d 1092, 305 N.E.2d 310. • 3 Under the Act (Ill. Rev. Stat. 1975, ch. 122, par. 24-11) after serving a two-year probationary period a teacher enters upon "contractual continued service" which continues until the teacher reaches 65 years of age. A tenured teacher may be dismissed for cause but such dismissal can be accomplished only by following the procedures prescribed by section 24-12 of The School Code. ( Gould v. Board of Education, 32 Ill. App.3d 808, 336 N.E.2d 69, 72; Miller v. Board of Education, 51 Ill. App.2d 20, 200 N.E.2d 838, 842.) Moreover it has been held that the Act is essentially procedural and thus must be strictly complied with in dismissing a tenured teacher.