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JUSTICE CERDA delivered the opinion of the court:

In this administrative review action, plaintiff, DarrylVeazey, appeals the order of the circuit court dismissing hiscomplaint which challenged the decision of defendants, theIllinois Department of Employment Security (the Department) andthe Department's Director, Linda Renee Baker, finding himineligible for unemployment insurance benefits following hisdischarge from defendant, Tele-Communications, Inc. In hiscomplaint, plaintiff named, among others not relevant to thisappeal, the Department and its director. The complaint, however,did not name the Department's Board of Review (the Board), whichissued the formal decision denying plaintiff's benefit request. Upon the motion of the Department and its director, the circuitcourt dismissed plaintiff's complaint for want of subject matterjurisdiction due to plaintiff's failure to name the Board as adefendant. The court thereafter denied plaintiff's request forleave to amend the complaint to add the Board as an adverseparty. On appeal, plaintiff asserts error in both the court'sdecisions dismissing his complaint and precluding him theopportunity to file an amended pleading. For the followingreasons, we affirm.

Generally, in unemployment compensation cases, the functionof this court is limited to determining whether the Board'sdecision denying the claimant benefits is supported by themanifest weight of the evidence. Fedorev v. Doherty, 305 Ill.App. 3d 355, 358-59, 711 N.E.2d 1223, 1225 (1999). However, inthis case, we are principally concerned with whether thedismissal of plaintiff's complaint for administrative review waswarranted. Since this issue presents solely a question of law,we will apply a de novo standard of review. Fedorev, 305 Ill.App. 3d at 359, 711 N.E.2d at 1225.

Section 3-102 of the Administrative Review Act (the Act)explicitly conditions review of an administrative decision uponcompliance within its provisions:

"Unless review is sought of anadministrative decision within the time andin the manner herein provided, the parties tothe proceeding before the administrativeagency shall be barred from obtainingjudicial review of such administrativedecision." 735 ILCS 5/3-102 (West 1998).

Indeed, as our supreme court has noted, the Act is a departurefrom the common law and, as such, its provisions must be strictlyadhered to by the parties. ESG Watts, Inc. v. Pollution ControlBoard, 191 Ill. 2d 26, 30, 727 N.E.2d 1022, 1025 (2000); FredmanBrothers Furniture Co. v. Department of Revenue, 109 Ill. 2d 202,210-11, 486 N.E.2d 893 (1985); see also Biscan v. Village ofMelrose Park Bd. Of Fire & Police Commissioners, 277 Ill. App. 3d844, 847, 661 N.E.2d 424, 427 (1996). Because administrativereview actions involve the exercise of special statutoryjurisdiction, the court's power to hear such cases is limited tothe language of the Act and, if the prescribed statutoryprocedure is not strictly followed, no jurisdiction can beinvoked. ESG Watts, 191 Ill. 2d at 30, 727 N.E.2d at 1025;Allord v. Municipal Officers Electoral Board for the Village ofSouth Chicago Heights, 288 Ill. App. 3d 897, 682 N.E.2d 125, 128(1997).

In addition to requiring a complaint for review to be filedwithin 35 days from the date a copy of the decision sought to bereviewed was served on the appealing party (735 ILCS 5/3-103(West 1998)), section 3-107(a) of the Act specifies that thecomplaint must name "the administrative agency and all persons,other than the plaintiff, who were parties of record to theproceedings before the administrative agency *** [as]defendants." 735 ILCS 5/3-107(a) (West 1998). As stated by oursupreme court, "[t]his requirement is mandatory and specific, andadmits of no modification." Lockett v. Chicago Police Board, 133Ill. 2d 349, 354, 549 N.E.2d 1266, 1268 (1990). Service ofsummons is the required on all party-defendants within the same35-day period in which the complaint for review is to be filed. 735 ILCS 5/3-103 (West 1998).

The law is undisputed that the Board is a necessary party toany administrative review action in which the denial of a claimfor unemployment insurance benefits is challenged. While theBoard may be a division or arm of the Department that operatesunder the superintendence of a director, it is the body that isdeemed to issue the administrative decision that is subject tothe review process and is, therefore, the "administrative agency"as that term is defined by the Act. 735 ILCS 5/3-102 (West1998); Cuny v. Annunzio, 411 Ill. 613, 617, 104 N.E.2d 780, 782(1952); Fedorev, 305 Ill. App. 3d at 359, 711 N.E.2d at 1226; NewYork Carpet World, Inc. v. Department of Employment Security, 283Ill. App. 3d 497, 500, 669 N.E.2d 1321, 1323 (1996); Shaw v.Department of Employment Security, 243 Ill. App. 3d 844, 846-47,612 N.E.2d 919, 920 (1993); Stanley v. Department of EmploymentSecurity, 235 Ill. App. 3d 992, 995, 602 N.E.2d 73, 75 (1992). Hence, when relief is sought from an adverse decision involving aclaim for unemployment compensation benefits, the Board is the"administrative agency" from which the plaintiff must seekreview. Fedorev, 305 Ill. App. 3d at 360, 711 N.E.2d at 1226;New York Carpet World, 283 Ill. App. 3d at 500, 669 N.E.2d at1323; Stanley, 235 Ill. App. 3d at 995-96, 602 N.E.2d at 75.

Plaintiff does not contest that the Board was a necessaryparty to his review action. Rather, plaintiff contends hisfailure to join the Board is not jurisdictional and, accordingly,the circuit court's determination that it lacked the authority toconsider the complaint was erroneous.

While some decisions have deemed the failure to name anecessary party under section 3-107(a) a jurisdictional defectthat will preclude a court from considering a complaint foradministrative review (see Biscan, 227 Ill. App. 3d at 847, 661N.E.2d at 427 ("[i]t is the proper filing of [the] complaintagainst all necessary parties that vests the court withjurisdiction to review the agency decision"); Central StatesTrucking Co. v. Department of Employment Security, 248 Ill. App.3d 86, 88, 618 N.E.2d 430, 432 (1993) (noting strict compliancewith the Act's provisions, including section 3-107, is necessarybefore the circuit court has power to consider complaint forreview); Associated General Contractors v. Chun, 245 Ill. App. 3d750, 754, 615 N.E.2d 386, 389 (1993) ("[a] plaintiff must namethe necessary parties as defendants in its complaint foradministrative review within the 35-day time limit or the courtis deprived of subject-matter jurisdiction"); Strang v.Department of Transportation, 206 Ill. App. 3d 368, 370-71, 564N.E.2d 261, 263 (1990) (holding that the plaintiff's failure toname the necessary parties in a timely manner deprived thecircuit court of subject matter jurisdiction). Our supreme courthas avoided such a characterization, instead holding that theeffect of noncompliance with the joinder requirements of section3-107(a), regardless of its label, requires dismissal of thereview proceeding. McGaughy v. Illinois Human Rights Commission,165 Ill. 2d 1, 11, 649 N.E.2d 404, 409-10 (1995) (finding thatDepartment of Human Rights was a necessary party to review actionand that plaintiffs' failure to name the department in theircomplaint required dismissal); Lockett, 133 Ill. 2d at 354, 549N.E.2d at 1268 (holding the plaintiff's failure to include thesuperintendent of police, who was a necessary party, as adefendant in the complaint, mandated dismissal of the action). As explained by the court, "the failure to join all necessaryparties is no less serious for being nonjurisdictional. McGaughy, 165 Ill. 2d at 11, 649 N.E.2d at 410. As McGaughy andLockett make clear, the characterization of plaintiff's failureto name the Board here as jurisdictional or nonjurisdictional isof no consequence since the result of plaintiff's noncompliancewith section 3-107(a) is the same in either case - dismissal ofhis complaint.

Alternatively, plaintiff argues that naming the director inher official capacity as the head of the Department wassufficient to join the Board under the Act. In support of hisposition, plaintiff cites to the portion of section 3-107(a) thatprovides:

"Naming the director or agency head, in hisor her official capacity, shall be deemed toinclude as defendant the administrativeagency, board, committee, or governmententity that the named defendants direct orhead. No action for administrative reviewshall be dismissed for lack of jurisdictionbased upon the failure to name anadministrative agency, board, committee, orgovernment entity, where the director oragency head, in his or her official capacity,had been named as a defendant as provided inthis Section. (Emphasis added.) 735 ILCS 5/3-107(a) (West 1998).

Based on the above language, plaintiff asserts that the naming ofthe Department's director as a defendant excused his failure toalso name the Board.

The same contention posited by plaintiff here has previouslybeen rejected by the court in Fedorev. There, the courtconsidered whether the director of the Department "directs orheads" the Board as contemplated by section 3-107(a). In findingthat the director does neither, the court relied on section 44aof the Civil Administrative Code of Illinois (20 ILCS 1005/44a(West 1998)), which provides in relevant part that the Board"shall exercise all powers and be subject to all duties conferredor imposed upon it by the provisions of the UnemploymentCompensation Act *** without any direction, supervision, orcontrol by the Director of Employment Security." (Emphasisadded.) Relying on the plain language of this section, the courtheld that the director, while the head of the Department, doesnot direct or head the Board for purposes of section 3-107(a). Fedorev, 305 Ill. App. 3d at 360, 711 N.E.2d at 1226.

We agree with the analysis of the Fedorev court and concludethat the naming of the director in plaintiff's complaint in thiscase is likewise insufficient to include the Board as adefendant. As previously stated, the Board is the relevantadministrative agency for purposes of seeking review under theAct and, while it may be deemed a part of the Department, it is,in essence, a separate and distinct entity for purposes of filingan action for review under the Act. Additionally, the recordhere, as the record demonstrated in Fedorev, shows that theDepartment's director had no part in the Board's determinationregarding plaintiff's eligibility for unemployment compensation. While naming the director in her official capacity would havebeen sufficient to include the Department as a defendant if thecomplaint had in fact not named the Department, it is inadequateto join the Board as a party.

In addition to failing to properly join the Board, plaintifffurther failed to comply with the Act's requirements concerningservice of summons. The record is undisputed that the Board wasnot served with summons in the manner and within the time periodset forth in sections 3-103 and 3-105.

The supreme court in Lockett held that, absent a good faitheffort on the party of the plaintiff to name and serve anecessary party as required by the Act, dismissal of thecomplaint for review, without granting the plaintiff leave toamend, is required. 133 Ill. 2d at 355, 549 N.E.2d at 1269. There, the court affirmed the dismissal of the plaintiff'scomplaint where the plaintiff failed to name and serve thesuperintendent of the Chicago police department, who was deemed anecessary party by the court. Because the plaintiff had notoffered, and since the record did not disclose, any evidence of agood faith effort to comply with the Act's requirements, thecourt held that the plaintiff's complaint was properly dismissedwithout affording the plaintiff the opportunity to file anamended pleading. Lockett, 133 Ill. 2d at 355-56, 549 N.E.2d at1268-69; see also Stanley, 235 Ill. App. 3d at 996-97, 602 N.E.2dat 75-76 (concluding that absence of evidence indicating that theplaintiff's failure to name and serve the Board of Review of theDepartment of Employment Security compelled affirmance of orderdismissing complaint for administrative review).

As in Lockett and Stanley, plaintiff has not offered, nordoes the record disclose, any evidence demonstrating a good-faitheffort on the part of plaintiff to name and serve the Board inaccordance with the Act. Plaintiff offers no reasonableexplanation for failing to join the Board as a defendant in thecomplaint. Undoubtedly, plaintiff's failure to timely serve theBoard with summons stemmed from his failure to join the Board inthe first instance. "The failure *** to [properly] name anecessary party as a defendant cannot be said to excuse thetimely service of summons or otherwise constitute a good-faitheffort in complying with the statute where *** the law clearlyrequired the Board [of Review of the Department] to be named as adefendant. Stanley, 235 Ill. App. 3d at 997, 602 N.E.2d at 76. The lack of evidence of a good-faith effort on plaintiff's behalfis fatal to plaintiff's complaint for administrative review and,thus, compels dismissal without leave to amend.

In a final attempt to defeat the effect of his failure tocomply with the Act, plaintiff claims the Department and itsdirector should be estopped from pursuing dismissal of hiscomplaint. In support of his contention, plaintiff notes thatthe caption of the Board's written decision reads, in descendingorder, "State of Illinois, Department of Employment Security,Board of Review." According to plaintiff, this caption inducesreliance and causes "anyone to believe" that the Department, andnot the Board, is the administrative agency that must be joinedin any action filed under the Act.

We do not believe plaintiff may rely on the estoppeldoctrine in this case. As explained by our supreme court, strictcompliance with the Act's provisions is mandated. Consequently,plaintiff was required to name all necessary parties in hiscomplaint. Despite the well-settled law in existence at the timeplaintiff commenced his action which clearly held that the Boardis the relevant administrative agency and, thus, a necessaryparty to any action filed for administrative review, plaintifffailed to join the Board in his complaint. Plaintiff, as adirect result, further failed to timely serve the Board withsummons. Plaintiff's claim of estoppel cannot negate hisnoncompliance with the Act. See Chun, 245 Ill. App. 3d at 754-55, 615 N.E.2d at 390 (rejecting the plaintiff's claim that theDepartment of Employment Security and its director were estoppedfrom challenging his pleading where the plaintiff failed to nameand serve the Department as expressly required by the Act). Inany event, plaintiff has never asserted that he substantivelyrelied on the Board's caption in determining which parties neededto be named as defendants in his complaint and, therefore, hasfailed to satisfy the necessary elements for application of theestoppel doctrine. See Halleck v. County of Cook, 264 Ill. App.3d 887, 893, 637 N.E.2d 1110, 1114 (1994) ("[t]o invoke equitableestoppel against a *** [public body] there must be an affirmativeact on the party of the *** [public body] and the inducement ofsubstantial reliance by the affirmative act").

For the following reasons, we affirm the dismissal ofplaintiff's complaint for administrative review without leave toamend to add the Board as a party-defendant.

Affirmed.

HALL, P.J., and BURKE, J., concur.