[2011] FWA 5091
The attached document replaces the document previously issued with the above code on 30 August 2011.
The document has been edited to correct typographical errors by replacing the word “Debarera” with the word “Dabarera.”
Dean Schubert
Associate to the Hon. Deputy President Sams, AM
Dated 30 August 2011
[2011] FWA 5091 |
|
DECISION |
Fair Work Act 2009
s 394 - Application for unfair dismissal remedy
Bianca Williams
v
Dtarawarra Pty Ltd t/a Dtarawarra Aboriginal Resource Unit
(U2010/14229)
DEPUTY PRESIDENT SAMS |
SYDNEY, 30 AUGUST 2011 |
Application for unfair dismissal remedy - dismissal for misconduct - unacceptable behaviour - racist comments - allegations against supervisor - procedural fairness - dismissal not ‘harsh, unreasonable or unjust’.
BACKGROUND
[1] Ms Bianca Williams (‘the applicant’) was employed as a Case Worker / Tenant Advocate by Dtarawarra Pty Ltd t/a Dtarawarra Aboriginal Resource Unit (‘the respondent’) from 19 January 2009. She was dismissed on 5 November 2010, with two weeks’ pay in lieu of notice, in a letter which stated the reason/s for her dismissal as her failure to provide “a reasonable explanation or to recognise the seriousness of your conduct as identified in the letter forwarded to you on Aug 17 2010”.
[2] The 17 August 2010 letter had directed the applicant to attend a disciplinary meeting on 25 August 2010 (later postponed to 2 September 2010) which might result in disciplinary action, including termination in relation to three issues of concern, primarily related to the applicant’s dealings with the respondent’s Acting Co-ordinator, Ms Cheryl Corbett; namely:
a) unacceptable behaviour and racist comments made by the applicant towards Ms Corbett; in particular, referring to her as a ‘mission manager’;
b) allegations made by the applicant in which she considered Ms Corbett had misused a Company vehicle, by using it on the weekends and had misused the vehicle’s petrol card; and
c) unreasonable demands by the applicant for which she had no authority to make, such as insisting that meeting minutes not be taken in short hand and demanding to view the vehicle log book.
[3] It was also said that her behaviour had forced Ms Corbett to seek medical advice and her doctor confirmed the enormous amount of stress she was under. Pending final resolution of the matter, the applicant was suspended on full pay. By letter dated 26 August 2010, the applicant’s Union, the United Services Union (‘the Union’), responded to the above allegations on the applicant’s behalf. The Union rejected items (a) and (b) above as not relating to the applicant’s conduct and rejected all of the respondent’s concerns as not relating to her performance.
[4] A disciplinary meeting at the Union’s office on 2 September 2010, was attended by the applicant, Ms Corbett, Ms Ruth de Costa (Director), Mr Thomas Russell and Mr Ben Thompson (from the Union). During the meeting, Ms de Costa handed the applicant a document which read as follows:
The matters listed below are provided to give Ms Bianca Williams the opportunity to respond:
1. Misconduct which is very serious and could warrant termination
2. “12th July 2010 you referred to Ms Cheryl Corbett as a “mission manager’ (sic). Ms Corbett was highly offended by your comment and told you so. You became very disgruntled at Ms Corbett and told her she had no right in organizing (sic) service visits with Prue from the Tenants Union without consulting you and the other tenant advocate.”
3. “19th July 2010 Ms Corbett asked you bout (sic) the location of the laptops and your reply was “around the place”. This request was not unreasonable as Ms Corbett had to get the serial number to be able to finish business. However I have great concerns about your response.”
4. “20th July 2010, on this day you again referred to Ms Corbett has (sic) a “mission manager” and that she had no right to be there. You questioned Ms Corbett’s use of the car and petrol card on the weekends and complained about the minutes.”
5. “23rd July 2010 you requested a meeting with Ms Corbett. Ms Corbett acknowledges that you had home visit and upon your return at 3.30 she informed you that she was ready but the meeting did not take place.”
6. “26th July 2010 a meeting was held Ms Williams raised a number of issues. However the issues of concern are the statement that Ms Corbett “is unbelievable”, the accusation that Ms Corbett was a buddy of the company to whom we purchased the computers from and again used the term “mission management.” Ms Williams also stated that she believed Ms Corbett altered the log book over the weekend.”
7. “4th August on this day you sent an email to Ms Corbett stating that the petty cash float has a limit of $300 and that at the time the balance was $133 and you demanded that Ms Corbett bring over the difference to make it up to $300. While it is policy that the limit of the petty cash is $300 the amount petty cash should be spent before the limit is replaced. In this email you also called Ms Corbett a dictator”.
I have serious concerns regarding your conduct and I must remind you that we are a small business that has limited human resources. Because of this and the number of complaints you have made over the 19 months of your employment we have suggested outside supervisions, mentoring which you have refused. We have requested that you write down your issues so that we can identigy strategies to make improvements but again you refuse to.
Both Cheryl Corbett and I have been in business for the last 16 years and have worked on and with Aboriginal Communities for the last 20 years. Ms Corbett has assisted with the development of a number of resources including Cross Cultural Packages and is fully aware of the horrific treatment which Aboriginal people suffered under the error of the Aboriginal Protection Board and the day of Mission Manager. And to referred to her has (sic) a “Mission Manager” is consider the most malicious term to someone that has not only devoted so much time to Aboriginal issues and community but to someone that’s work ethic is not that of a boss mentality.
[5] The meeting was adjourned at the Union’s insistence as it was said that these matters constituted new allegations which the applicant needed time to consider and respond to. The applicant responded to the above matters by generally rejecting all of them. She was subsequently dismissed on 5 November 2010.
[6] On 17 November 2010, the applicant lodged an application for an unfair dismissal remedy, pursuant to s 394 of the Fair Work Act 2009 (‘the Act’). The matter was unable to be resolved during a telephone conciliation on 7 December 2010. Subsequently, the respondent filed an objection to the application on the basis that:
a) the applicant’s dismissal was consistent with the Small Business Fair Dismissal Code (‘the Code’); and
b) the application was frivolous and/or vexatious. This objection was not pressed by the respondent in the arbitration.
THE EVIDENCE
[7] The following persons gave evidence in the proceedings:
Ms Bianca Williams, the applicant
Mr Thomas Keith Everall Russell, Support Team Officer, United Services Union
Mr Ben John Thompson, United Services Union
Ms Ruth Simone de Costa, Director and Company Secretary, Dtarawarra Aboriginal Resource Unit
Ms Cheryl Corbett, Program Co-ordinator, Dtarawarra Aboriginal Resource Unit
Mr Tim Rowse, Professorial Fellow, Centre for Citizenship and Public Policy, University of Western Sydney
Applicant’s Evidence
[8] The applicant said that on a number of occasions during February and March 2010, the respondent’s then Co-ordinator, Ms Stacey Broadbent (with whom she was friendly) had told her, in Ms Corbett’s presence, that she would be recommending her to Ms de Costa for the Acting Co-ordinator’s position. On Ms Broadbent’s last day of work, she again told the applicant she would be recommending her for the acting role.
[9] On 22 April 2010, the applicant questioned Ms Corbett about the position and was told that Ms de Costa had an unsigned letter of complaint about the applicant, purportedly from Ms Broadbent. On 23 April 2010, when the applicant asked Ms de Costa how she should respond to the complaint, Ms de Costa told her that Ms Corbett had been successful in obtaining the Acting position. The applicant believed that as Ms Corbett and Ms de Costa were friends outside work and had had a business relationship for 20 years, that this relationship influenced the respondent’s decision to appoint Ms Corbett.
[10] The applicant said that she made numerous attempts to call and email Ms de Costa to discuss the acting position and the alleged complaint, but did not meet with her until 4 June 2010. The applicant said that Ms de Costa told her that the complaint was unsigned because she had prepared the letter herself after a verbal complaint from Ms Broadbent. The applicant acknowledged that this matter was not raised again after this meeting.
[11] The applicant said that soon after the Co-ordinator’s position was advertised, she had applied for the job and Mr Jim Allen, Co-ordinator of the Batemans Bay Service, agreed to be her referee. However, he had to withdraw, as he was on the interview panel. On 18 June 2010, the applicant was advised that her application was unsuccessful. The applicant believed that she was disadvantaged and unfairly treated, particularly as she was later informed that the successful candidate had superior references. The successful candidate decided not to take the position and Ms Corbett retained the Acting Co-ordinator’s role.
[12] The applicant claimed that Ms Corbett did certain things which made her work difficult. These included interrupting her while she was speaking to clients and identifying the applicant as receiving a client’s call when Ms Corbett had.
[13] On 20 July 2010, the applicant raised with Ms Corbett the issue of the log book not being in the work vehicle. Ms Corbett said the book had been removed due to damaged pages and would be available at the next scheduled staff meeting on 26 July 2010. At this meeting, the applicant complained that the minutes were taken in short hand and she did not agree with the minutes of the last meeting. The applicant said that Ms Corbett refused to have minutes taken in long hand and responded to subsequent questions and comments put by the applicant by grunting. In frustration, the applicant said ‘your actions are that of a real mission management mentality’.
[14] The applicant claimed that at the 2 September 2010 meeting, she apologised to Ms Corbett if she was offended by the reference to ‘mission manager’. The applicant said Ms de Costa then handed her a letter with new allegations. As a result, the Union put an end to the meeting as she would need more time to respond properly. Ms de Costa had replied that they (the respondent) would not be ‘participating in anything else.... that’s the end of it’.
[15] In November 2010, the position of Co-ordinator was re-advertised. The applicant claimed that she had a good work record and enjoyed good relationships with the clients of the Service.
[16] In oral evidence, the applicant believed that the 2 September 2010 meeting was for the purposes of mediation in order to work out a resolution of the workplace issues. She had apologised to Ms Corbett. She claimed she had only used the term ‘mission management’ on two occasions - once to Ms de Costa and again in the staff meeting on 26 July 2010. When she had said it to Ms de Costa the applicant claimed that she had not responded. The applicant said her understanding of the term ‘mission management’ could relate to anyone in authority who uses their authority for their own outcomes. The applicant said Ms Corbett did not have a discussion with her in relation to her performance or conduct prior to the 17 August 2010 letter.
[17] In cross-examination, the applicant acknowledged attending cross cultural training, which included the history of ‘mission managers’ as managers who were cruel and oppressive toward Aboriginal people.
[18] The applicant agreed she had a good relationship with Ms Corbett in the three years before she took on the Acting Co-ordinator’s role. She denied their relationship soured over Ms Corbett’s appointment. She believed their relationship changed after she had raised matters in the workplace which were not followed appropriately, and despite the issues being raised with Ms Corbett.
[19] In relation to the alleged unfair treatment over Mr Allen withdrawing as a referee, the applicant accepted that Mr Allen’s decision was not the responsibility of the respondent. However, she believed there may have been some ‘underlying issue’.
[20] In further oral evidence, the applicant agreed:
• she did not display any long term commitment to the respondent. However, some underlying issues had not been addressed for six weeks’ and others not at all;
• she had said to Ms de Costa ‘Don’t be surprised if I’m gone by the time you get back from long service leave’. She said that this comment was made in the context of being upset about the referee issue and the unsigned letter of complaint;
• she had told Ms Corbett she was unprofessional and unqualified;
• that Ms Corbett would translate the minutes from short hand into long hand;
• she had accused Ms Corbett of using the work vehicle and petrol card for personal use, without any knowledge of how the petrol had been paid;
• she knew Ms Corbett was allowed the vehicle for personal use;
• she had told Ms Corbett ‘you’re unbelievable’ when she had told her to take the minutes herself;
• she had said to Ms Corbett in respect to the purchase of new Apple computers ‘Did you get your mates to do that?’ and that she was suggesting impropriety. She claimed she based her allegation on conversations in the office with other employees;
• she had said to Ms Corbett ‘I think you’re using the co-ordinator situation to your own benefit. Someone else should have been hired,’
• she had intended to suggest Ms Corbett had obtained some advantage from her position;
• she said in respect to the use of the vehicle ‘You changed the entries to cover up your personal use of the car... you’ve done stuff like that before. You probably typed the letter of appointment for the acting position yourself’;
• she had accused Ms Corbett of ‘dictating’ by email;
• in the meeting of 2 September 2010, Ms de Costa had said Ms Corbett found the ‘mission manager’ comment ‘extremely hurtful’ and Ms de Costa said it was ‘one of the highest insults that you could call another person’;
• she had called Ms Corbett a ‘mission manager’ again during this meeting;
• she had apologised to Ms Corbett for hurting her feelings, but not for the words used;
• she was given three opportunities to respond to the allegations - at the 2 September 2010 meeting and in two later written responses;
• believed it was inappropriate for Ms Corbett to fill the Acting Co-ordinator’s position, as she was not ‘indigenous’, as she understood it was an Aboriginal identified position;
• she was unable to verify Ms Corbett’s Aboriginality; and
• that since her dismissal she had only applied for one position, for which a decision was to be made in May 2011.
[21] In further evidence, the applicant denied:
• knowledge of Ms Corbett’s injury preventing her from taking minutes in long hand;
• following Ms Corbett around in an intimidating fashion;
• that Ms Corbett had told her she had obtained a quote for the computers;
• her allegations against Ms Corbett were untrue; and
• not apologising to Ms Corbett in the 2 September 2010 meeting.
[22] However, the applicant could not recall using the term ‘mission manager’ at the 12 July 2010 meeting, or whether Ms Corbett told her ‘I take offence to that’.
[23] Mr Thompson attended the 2 September 2010 meeting. He believed the applicant genuinely apologised to Ms Corbett early in the meeting for any offence caused by calling her a ‘mission manager’.
[24] Shortly thereafter, Ms de Costa told the applicant she considered her conduct constituted serious misconduct and handed her a letter. After reading the letter, the applicant said it contained new allegations which she and the Union had not been made aware of. Mr Thompson suggested that the meeting should end to allow the applicant an opportunity to respond to the new allegations.
[25] In oral evidence, Mr Thompson agreed that he attended the meeting to support the applicant, and was not an observer. He believed the letter given to the applicant contained new allegations and this was the reason for ending the meeting, in order for her to respond to them. He could not recall Ms de Costa telling him to contact the Department of Fair Trading to establish whether the Co-ordinator’s role was an Aboriginal identified position. He could not recall saying this was a significant issue for his client’s case. He had no further involvement in the matter.
[26] Mr Thompson conceded that the applicant did use the term ‘mission manager’ in the meeting, but only in the context of a discussion of its historical meaning. He could not recall if the applicant directed the term toward Ms Corbett.
[27] Mr Russell said that during 2 September 2010 meeting, the parties had discussed the applicant’s request to have minutes of staff meetings taken in long hand. She had apologised to Ms Corbett if she had taken offence to the use of the words ‘mission manager’.
[28] Mr Russell said that about half way through the meeting, Ms de Costa handed the applicant a document containing new allegations. She had not told the applicant or the Union that these allegations would be raised. The applicant reacted in such a way as to make it clear that she had had no notice of these new allegations. Mr Russell said that the applicant indicated that she did not want to deal with these new allegations at that time. However, Ms de Costa said that this would be the only meeting. Mr Thompson had said that the meeting should end so as to allow the applicant an opportunity to respond. However, Ms de Costa said ‘I want to get this over now’ and implied there would be no further meetings or discussions. As Ms de Costa was leaving she said ‘you’ll be hearing from my lawyer’.
[29] In oral evidence, Mr Russell deposed that the Union did not consider that the letter of 17 August 2010 raised issues of performance. It was the Union’s understanding that the meeting of 2 September 2010, was convened for the purpose of addressing unresolved matters from this letter. It was basically a good faith or goodwill meeting that would not have binding outcomes. He explained this in cross-examination by indicating that the Union convened the meeting as a mediation to assist the applicant, and the Union was not necessarily speaking on her behalf. He accepted that the respondent’s letter suspending the applicant did not refer to the proposed meeting as a mediation. However, the Union’s letter in reply had done so.
[30] Mr Russell believed the document given to the applicant in the meeting contained new allegations. He denied that the applicant had again called Ms Corbett a ‘mission manager’. He believed her apology was sincere as she had not apologised in a sarcastic manner. Her repetition of the phrase was simply when she was discussing the term’s definition.
[31] Mr Russell acknowledged that the Union had contributed to the delay in dealing with this matter - but only by eight days.
[32] In questioning from the Bench, Mr Russell was asked about the Union’s practice of arranging mediations. He accepted that the Union’s participation was in support of its member. He said that the applicant’s worksite was categorised as a ‘priority 3’ site (having fewer than five members). This meant that the employer was invited to the Union’s offices to discuss any problems, but the Union would otherwise be unable to support the member in further disciplinary proceedings. Mr Russell said that after the 2 September 2010 meeting had broken down, he expected the respondent would agree to its request for at least one further meeting to discuss any disciplinary outcomes.
Respondent’s Evidence
[33] Ms de Costa established the business in 1996. It only ever had a maximum of five employees. Ms Corbett had been a Director until 2007 and had been an employee in management since 1996. Ms de Costa said the respondent has no dedicated human resources manager; that function was undertaken by her.
[34] Ms de Costa said that in January 2010, Ms Broadbent spoke to her about the applicant’s aggressive tone and attitude towards Housing New South Wales staff and her concern as to what effect this behaviour would have on the respondent’s relationship with Housing New South Wales.
[35] In response to Ms Broadbent’s concerns, Ms de Costa said she had organised training in February 2010 for all staff on effective communication skills for advocates. In addition, all new employees attend cross-cultural training. The applicant attended this training on 17 March 2009. The training included reference to ‘mission managers’. Ms de Costa attached to her statement the respondent’s policies, induction kit, training agenda and training booklet.
[36] On 1 April 2010, Ms Broadbent told Ms de Costa that she had received an aggressive phone call from the applicant concerning underpayment of her holiday pay. Ms de Costa said she prepared a statement of Ms Broadbent’s account of what had happened and Ms Broadbent confirmed it was accurate. Ms Broadbent said she would sign the statement and return it to her. On 23 April 2010, Ms Broadbent sent Ms de Costa an email confirming she had posted a signed copy of her statement. However, it was not, and has not, been received.
[37] Ms de Costa said that on that same day, she had received an angry telephone call from the applicant in which she said that she and ‘Jenny’ had had an altercation and she needed to go on stress leave. The applicant also enquired about who would be filling the Acting Co-ordinator’s role. Ms de Costa told her Ms Corbett would be filling the role until the job was advertised, interviews held and the position filled. The applicant expressed concern about Ms Corbett taking on the role as a volunteer, but her meaning of this concern was unclear to Ms de Costa and she asked her to put any concerns in writing. The applicant did not do so and did not go on stress leave. Ms de Costa denied telling the applicant that Ms Corbett was volunteering in the Acting Co-ordinator’s role. Ms de Costa claimed that she was unaware of the applicant’s allegations of Ms Corbett’s interference in her work, until she had read the applicant’s statement in these proceedings.
[38] Ms de Costa claimed that she had planned to discuss the holiday pay phone call with the applicant, but due to a serious car accident and work commitments she could not do so until a staff meeting on 4 June 2010. In the interim, she had asked Ms Corbett to give the applicant a copy of Ms Broadbent’s unsigned statement. After discussing the matter at the staff meeting, no further action was taken over the phone call issue. Ms de Costa denied that Ms Broadbent had ever recommended the applicant as suitable for the Co-ordinator’s position. It was not an Aboriginal person identified position.
[39] Ms de Costa said that on 18 June 2010, she notified the applicant that she had been unsuccessful in her application for the Co-ordinator’s position. The applicant had then threatened to leave by the time Ms de Costa returned from long service leave as she had to ‘put up with Cheryl and her mission management style’. Ms de Costa did not respond to her. Between 18 June and 16 August 2010, Ms de Costa was on long service leave.
[40] Ms de Costa said that the respondent had no involvement in Mr Allen’s decision not to act as the applicant’s referee and, in any event, she had sufficient time to provide a replacement. She denied telling the applicant that the successful candidate was preferred partly because of his referees.
[41] The day after returning from leave, Ms Corbett told Ms de Costa that she was on sick leave because of the stress at work and that her doctor had told her not to return to work. She informed Ms de Costa that the applicant had called her a ‘mission manager’ or having a ‘mission management style’ on three occasions in July 2010 and she had been very offended. She had told the applicant she had been offended. Ms Corbett also told her of other concerns with the applicant’s conduct towards her during her absence. This conversation resulted in the applicant’s suspension on full pay. Ms de Costa added that on 19 August 2010, the applicant wrote to the Department of Fair Trading making complaints about a number of issues in respect to the respondent.
[42] Ms de Costa said that a formal disciplinary meeting had been scheduled for 25 August 2010, but had to be cancelled due to the unavailability of an independent chairperson. The meeting was rescheduled at the Union’s offices on 2 September 2010. Ms de Costa said her notes of this meeting record that the applicant had denied the term ‘mission manager’ was racist. She had used the term against Ms Corbett again during the meeting. At no time did the applicant apologise to Ms Corbett. Her notes also confirm that she was not happy when the meeting was brought to an end. She indicated she would be seeking legal advice because the matter was taking too long to resolve. However, she denied saying that she considered the matter was at an end.
[43] Ms de Costa denied that new allegations were brought against the applicant during the meeting. They were consistent with those raised in the 17 August 2010 letter and, in any event, the applicant had two later opportunities to respond to the allegations. Ms de Costa believed the Union had brought the matter to an end because it was confused about the reporting hierarchy at Greater Sydney Area Tenancy Service and had wanted to clarify this issue before progressing with the meeting. On 14 September 2010, Ms de Costa received an email from Mr Russell attaching the applicant’s response to the issues raised during the meeting.
[44] On 18 October 2010, Ms de Costa wrote to Mr Russell providing Ms Corbett’s comments to the applicant’s responses. The added time taken to do this was due to workload and her own health issues. On 28 October 2010, Ms de Costa received an email from Mr Russell attaching a further response from the applicant.
[45] Ms de Costa said she had carefully considered the applicant’s written responses and the 2 September 2010 meeting and concluded that the applicant had shown no remorse, particularly as she had referred to Ms Corbett as a ‘mission manager’ again during the meeting. She decided to dismiss the applicant for serious misconduct but, nevertheless, paid her two weeks’ in lieu of notice.
[46] Ms de Costa agreed that she and Ms Corbett had a long history of being in business together, but this relationship had nothing to do with the applicant’s employment, the disciplinary process or the decision to terminate her employment.
[47] Ms de Costa said she had a serious heart condition which meant that she should minimise stress. She had found working with the applicant stressful and she could not tolerate her aggressive attitude in the workplace. In these circumstances, she believed that reinstatement was inappropriate.
[48] In cross-examination, Ms de Costa explained that she had asked Ms Corbett to give the applicant Ms Broadbent’s unsigned complaint, because Ms Broadbent had told her, on a number of occasions, that she had signed it. She had believed that giving the complaint to the applicant would bring things out in the open and give them all a chance to discuss and resolve the matter.
[49] When questioned as to why she did not respond to the applicant’s use of the term ‘mission management’ on the first occasion, Ms de Costa deposed that she had not wanted to make a fuss and escalate the issues prior to her taking leave. In addition, she did not believe that the applicant would use the term directly to Ms Corbett. Ms de Costa acknowledged that she did not consider the applicant’s behaviour, at that stage, amounted to serious misconduct. Ms de Costa said she had not raised the applicant’s use of the term before the 17 August 2010 letter, because she had only been advised of Ms Corbett’s concerns, when she returned from leave.
[50] In her statement, Ms Corbett claimed the applicant had had issues with her previous employer, Tranby Aboriginal College, when they had both worked there. Nevertheless, Ms Corbett agreed she had recommended the applicant for her job with the respondent.
[51] Ms Corbett said that the applicant did not respond well to her being appointed as the Acting Co-ordinator. She had appeared upset and resentful. For example, on 12 July 2010, the applicant had confronted her about her role as Acting Co-ordinator and had said ‘you are like a mission manager’. When she took offense at the remark, the applicant responded with allegations that she had misused the respondent’s vehicle. The applicant had also described her as unprofessional and unqualified. Ms Corbett told her to put any allegations in writing. She believed the applicant was aggressive during this conversation and she well knew the significance of being called a ‘mission manager’. Again on 19 July 2010, the applicant was short and dismissive when Ms Corbett had asked her where the laptops were. The applicant had responded with ‘around the place’.
[52] On 20 July 2010, the applicant again accused Ms Corbett of misusing the vehicle and petrol card for personal use. She had demanded to see the log book, called her a ‘mission manager’ again and added ‘you have no right to be here’. Ms Corbett said she had felt bullied and harassed. The applicant had also followed her around the office and tried to stand close to her. Ms Corbett believed this behaviour was very intimidating and she had not felt safe.
[53] Ms Corbett indicated that she occasionally used the work vehicle on the weekends. However, this was in accordance with the respondent’s policy. She had recorded her use of the vehicle and paid for the petrol herself.
[54] At the monthly staff meeting on 26 July 2010, when the applicant complained about the minutes being taken in short hand, Ms Corbett told her that she could take responsibility for taking the minutes in long hand. (Ms Corbett had a hand injury which prevented her taking notes in long hand.) The applicant had remarked ‘you are unbelievable’. The applicant had accused her, by implication, of improperly dealing with the purchase of Apple computers for the office from a friend. The applicant accused her of using the Acting Co-ordinator’s position for her own benefit and had said somebody else should have been hired. She mentioned ‘mission management’ again and had said an Aboriginal person should have been employed. She further alleged that Ms Corbett had taken the vehicle log book home to change the entries in order to ‘cover up’ the personal use of the vehicle. In addition, she alleged that Ms Corbett had typed up her own letter of appointment which Ms de Costa was probably aware of. She had continued to say ‘you shouldn’t even be here’.
[55] Ms Corbett found this meeting stressful and offensive. She had felt weak and unwell and had a ‘burning headache’. When she consulted her doctor, she was diagnosed with high blood pressure and was directed not to go back to work while the applicant was at the workplace. She was referred to a heart specialist for further testing and certified unfit for work until 20 August 2010.
[56] Ms Corbett also referred to an email exchange with the applicant on 4 August 2010, in which the applicant accused her of ‘dictating’ to her. Ms Corbett said she had spoken to Ms de Costa about the applicant’s behaviour around 17 August 2010.
[57] Ms Corbett gave her version of events of the 2 September 2010 meeting. The applicant had not apologised to her then, or ever, for using the term ‘mission manager’. She had accused Ms Corbett of being unprofessional and unqualified. Ms Corbett denied interrupting or acting aggressively towards the applicant at the meeting. She agreed she had queried the applicant’s qualifications, but not in a derogatory way. When the Union closed the meeting, it was agreed that the applicant would respond in writing to the allegations of misconduct. Ms de Costa had never said the matter was closed.
[58] Ms Corbett said that Ms Broadbent had never recommended the applicant to her for the Acting Co-ordinator’s position and she had no knowledge of Ms Broadbent ever making such a recommendation to Ms de Costa. Ms Corbett denied that she had ever deliberately interrupted the applicant or interfered with her work.
[59] Ms Corbett denied her friendship and business relationship with Ms de Costa had any effect on the applicant’s employment. She had not been consulted about the decision to terminate the applicant’s employment. Ms Corbett continues to work for the respondent and believes that she could never work with the applicant again. She felt the applicant’s comments had denigrated her and affected her confidence. She had felt anxious and was not enjoying her work. She could not take any further abuse from the applicant and did not think she could work in the applicant’s team.
[60] In cross-examination, Ms Corbett deposed that she did not:
• have any discussion with the applicant about the term ‘mission manager’, apart from saying she was offended by it;
• have any discussion with the applicant over the ‘laptops incident’, because she felt it would be a useless exercise;
• raise with the applicant that the use of the term ‘mission manager’ could be considered misconduct in a workplace context. She said she did not do so as the applicant was well aware what ‘mission manager’ meant, as did every Aboriginal person; and
• recommend to Ms de Costa that she terminate the applicant’s employment.
[61] Mr Rowse has researched and written about Aboriginal indigenous history since 1981. He said that when used by an Aboriginal person, the term ‘mission manager’ would ordinarily have negative connotations. This arose from the historical context from which the term is derived. Mr Rowse concluded:
“It is difficult to imagine that the term ‘mission manager’ would not carry pejorative meaning when used by an Aboriginal person of New South Wales. As a figure in Aboriginal oral tradition, ‘mission manager’ connotes the worst features of White officialdom as Aborigines experienced it: petty tyranny, a proclivity for mental and physical cruelty, cultural insensitivity, even threat to family security (his power to report unfavourably on a family unit could justify the official removal of children).”
SUBMISSIONS
For the applicant
[62] It was Ms N Dabarera’s submission that the applicant’s dismissal was inconsistent with the Code in that the dismissal was not a summary dismissal (she was paid in lieu of notice) and the respondent must give the employee a reason why she was at risk of being dismissed and the reason must be a valid reason.
[63] Ms Dabarera said that the three allegations noted in the 17 August 2010 letter were vague and undefined and were therefore not a valid reason for the dismissal. The applicant was not given an opportunity to improve her behaviour because she was placed on immediate suspension after receiving the 17 August 2010 letter: see Dianna Smith v Fitzgerald [2011] FWAFB 1422. Rectifying her behaviour might include additional training and ensuring she understood the respondent’s expectations. The applicant was willing to take steps to rectify her behaviour by apologising for the ‘mission management’ comment. Ms Dabarera added that Ms Broadbent’s complaint was never handled properly or allowed to be addressed by the applicant.
[64] In further submissions, Ms Dabarera said that serious misconduct must be “significantly worse than negligence and serious in its culpable quality as misconduct, as distinct from the results”: see Jarvis v Anderson Plumbing & Roofing Pty Limited [2010] FWA 8896 at para 10. She said the respondent’s own conduct was inconsistent with the applicant having engaged in serious misconduct, in that:
• Ms de Costa did not respond to the ‘mission manager’ comment on 18 June 2010 because she ‘didn’t want to make a fuss’; so she did not even bring to the applicant’s attention that she considered the term to be of a serious nature;
• on the 12 July 2010, Ms Corbett merely allegedly said in response, ‘I take offence to that’;
• on the 20 July 2010, Ms Corbett merely told the applicant to put her complaints in writing; and
• during the 26 July 2010, at a staff meeting, when the applicant allegedly made another reference to ‘mission management’, Ms Corbett merely responded with, ‘Let’s move on to the next point in the minutes’.
[65] Ms Dabarera noted that the respondent did not inform the applicant, until the 17 August 2010 letter, that her conduct constituted serious misconduct and that a repeat might result in disciplinary action, including termination of employment. Ms Dabarera noted that the applicant was not told that her dismissal was for an unwillingness to follow directions or for bullying. There was not enough detail to enable her to respond effectively. She was therefore not provided with an opportunity to respond to these allegations: see Rapp v Wauchope RSL Club Ltd [1995] NSWIRComm 233.
[66] Ms Dabarera put that the applicant had a right to raise issues about the minutes being taken in short hand, requesting to see the vehicle log book and raise questions about whether the respondent’s policies were being followed.
[67] As to the matters in s 387 of the Act, Ms Dabarera submitted as follows:
i. There was no valid reason provided for the applicant’s dismissal.
ii. Termination purported to be for failing to ‘provide a reasonable explanation or recognize the seriousness of your conduct” but that due to the vagueness of the allegations “identified in the letter forwarded to [her] on August 17 2010” it is procedurally unfair to expect her to defend herself against them.
iii. Attached to the respondent’s form F4 is a copy of a completed Small Business Fair Dismissal Code Checklist (the Checklist). The Checklist states the applicant was dismissed for “Racist Conduct and Unwillingness to follow directions from acting coordinator” but none of the correspondence stated the applicant was being dismissed, or at risk of dismissal, for “unwillingness to follow directions from acting coordinator”. As the applicant was never informed of this allegation, she was not afforded the opportunity to respond to it.
iv. The Checklist further made reference to Ms Corbett’s health problems and underneath that reference extracted a definition of bullying, but none of the correspondence made a link between the applicant’s behaviour in the workplace and Ms Corbett’s alleged health problems. Further, the allegation of bullying was never raised during the disciplinary or dismissal process and the applicant was not afforded the opportunity to respond to it.
v. The applicant was never afforded the opportunity to amend her work performance or conduct following the 17 August 2010 as she was placed on continuous suspension from that time until her dismissal.
vi. The length of the suspension was excessive and created unnecessary uncertainty for the applicant and her family.
[68] The applicant sought reinstatement with no loss of continuity and payment for lost wages. In the alternative, maximum compensation should be ordered by FWA.
For the respondent
[69] Mr J Pomeroy raised no jurisdictional issues in respect to this case. He contended that the applicant was dismissed for:
(a) On 3 separate occasions, she described Ms Corbett as a “mission manager” or engaging in “mission management”. The second and third occasions occurred despite the applicant being made aware that Ms Corbett found the descriptions offensive;
(b) alleging without foundation that Ms Corbett was misusing company resources;
(c) alleging without foundation that Ms Corbett improperly selected the supplier of computers for the service;
(d) demanding that Ms Corbett not take minutes of staff meetings in short hand; and
(e) accusing her of “dictating” to staff in her role as Acting Coordinator.
He noted that the applicant had provided written responses to the allegations on 14 September and 28 October 2010.
[70] Mr Pomeroy submitted that the applicant’s dismissal was consistent with the Code in that:
i. It is not necessary for an employee to be summarily dismissed for the summary dismissal provisions of the Code to apply so long as the employer had formed the appropriate belief regarding the seriousness of the employee’s conduct. In this case the respondent had formed such a belief about the seriousness of the applicant’s conduct and this is supported by Ms de Costa’s witness statement and by the 2 September 2010 document that stated the allegations against the applicant may amount to misconduct.
ii. Not only had the respondent formed the appropriate belief but it had reasonable grounds for doing so as the applicant engaged in repeated abusive and offensive behaviour towards Ms Corbett and raised unfounded allegations against her. The respondent submits that this behaviour constituted serious misconduct.
iii. As the applicant’s behaviour constituted serious misconduct, the respondent had no obligation to provide her with prior warning of dismissal.
[71] In addition, Mr Pomeroy said the applicant’s dismissal was not ‘harsh, unreasonable or unjust’ in that:
i. There were valid reasons for the applicant’s dismissal, including:
• the applicant’s use of offensive and abusive terms towards Ms Corbett on 3 occasions during July 2010, with the knowledge that these terms offended Ms Corbett, and notwithstanding training that had been given by the respondent in relation to missions, their managers and the associated mistreatment of Aboriginal people;
• the applicant had not apologised for the use of these terms and in fact used the term again during the 2 September 2010 disciplinary meeting (in direct contradiction to the applicant’s submissions);
• a) Telling the acting coordinator on 3 separate occasions that she was a “mission manager” or engaged in “mission management” and the second and third occasion were subsequent to her being made aware that Ms Corbett found those terms offensive;
b) Alleging, without foundation, that Ms Corbett was misusing company resources;
c) Alleging, without foundation, that Ms Corbett improperly selected the supplier of computers for the service;
d) Demanding that Ms Corbett not take minutes of staff meetings in short hand; and
e) Accusing Ms Corbett of “dictating” to staff in her role as acting coordinator.”
• these reasons were sufficiently particularised in the “disciplinary matters” document that was provided to the applicant at the 2 September 2010 disciplinary meeting, even if the 17 August 2010 letter had only made reference to them in general terms.
ii. The applicant was notified of the reasons for her dismissal:
• by the letter dated 17 August 2010;
• during a meeting between the applicant, the Union, and the respondent on 2 September 2010; and
• by the letter dated 5 November 2010.
iii. The applicant was given the opportunity to respond to those reasons:
• during the 2 September 2010 meeting;
• in writing on 14 September 2010; and
• in writing on 28 October 2010.
iv. The applicant was given the opportunity to have a support person present:
• At all relevant times the applicant was represented by the Union and the 2 September 2010 meeting was also held at the Union’s premises.
v. The relatively small size of the respondent’s enterprise:
• The disciplinary, investigative and dismissal processes were fair and appropriate in these circumstances. As for the time taken to conclude investigations, the Union had contributed to this delay.
vi. The respondent had no dedicated human resources function:
• Ms de Costa was responsible for staffing issues and had to deal with business commitments between 14 September 2010 and 5 November 2010, in addition to seeking advice in relation to the dismissal procedure, as she is not a specialist in human resources.
[72] Mr Pomeroy put that the application should be dismissed. However, if FWA found to the contrary, reinstatement was inappropriate given the small workplace and the applicant’s interaction with Ms Corbett.
[73] Mr Pomeroy further submitted that pay in lieu of notice does not mean that the reason for dismissal could not be misconduct: see Murray v Electric Light Hotel [2010] FWA 2613. In any event, the respondent’s actions were not inconsistent with summary dismissal. That is, Ms de Costa was overseas on long service leave for some time and Ms Corbett was Acting Co-ordinator. She could not brief Ms de Costa until her return and Ms de Costa acted almost immediately upon being informed of the applicant’s behaviour.
[74] Mr Pomeroy submitted that the applicant’s conduct could not be understated and arose soon after her unsuccessful application for the Acting Co-ordinator’s position. She thereupon engaged in a deliberate course of harassment, intimidation and derogatory language at various times in July 2010. This was in the context of telling Ms de Costa ‘I may not be around when you return from long service leave’. Mr Pomeroy maintained that the patterns of consistency of the applicant’s abuse, in the face of Ms Corbett’s objections, entitled the respondent to dismiss her summarily.
[75] In closing submissions, Mr Pomeroy put that from the time Ms Corbett took up the Acting Co-ordinator’s role, the applicant was not prepared to accept her authority, nor her word. She contested the validity of Ms Corbett’s appointment and then, over the course of the next four months, refused on numerous occasions to accept her authority. She had raised various unfounded allegations, such as improper treatment of a computer contract, misuse of the respondent’s vehicle and petrol card and whether Ms Corbett was a proper person for the Acting Co-ordinator’s role.
[76] Mr Pomeroy said that Ms Corbett was subject to personal abuse by the use of the term ‘mission manager’, which, while not being racist, was one of the highest insults in Aboriginal culture. The applicant used the term knowing exactly what it meant. Mr Rowse’s uncontested evidence confirmed how offensive the term was. By its repeated use in the face of cross cultural training and the applicant’s personal knowledge, the applicant compounded her misconduct.
[77] Mr Pomeroy submitted that there were no issues of procedural unfairness. The 17 August 2010 letter set out the disciplinary process, the Union was involved at all relevant times and the applicant had three opportunities to respond to the allegations, and did so with advice. The allegations were not vague or imprecise. As the applicant had responded directly to them, she must have known what they entailed.
[78] Mr Pomeroy observed that the applicant had not sought to mitigate her loss, given she had only applied for one position since 5 November 2010. He said that reinstatement would be inappropriate, in that Ms Corbett still works part time and the applicant’s position had been filled. Mr Pomeroy conceded that ‘bullying’ had not been given as a reason for dismissal, but some of her conduct could easily fit that description. He also acknowledged that the fact the applicant’s position had been filled was not an insurmountable barrier to reinstatement, should FWA consider it appropriate.
CONSIDERATION
The legislation and relevant principles
[79] There is no dispute that:
a) the applicant was a person protected from unfair dismissal (s 382 of the Act);
b) the applicant was dismissed from her employment at the initiative of the employer with two weeks’ pay in lieu of notice (s 386 of the Act);
c) the respondent was a small business employer (s 23 of the Act); and
d) the applicant’s dismissal was not a case of genuine redundancy (s 389 of the Act).
[80] Some controversy arose in this case as to whether the Code was appropriately applied to the applicant’s dismissal. The Code provides:
Summary Dismissal
It is fair for an employer to dismiss an employee without notice or warning when the employer believes on reasonable grounds that the employee’s conduct is sufficiently serious to justify immediate dismissal. Serious misconduct includes theft, fraud, violence and serious breaches of occupational health and safety procedures. For a dismissal to be deemed fair it is sufficient, though not essential, that an allegation of theft, fraud or violence be reported to the police. Of course, the employer must have reasonable grounds for making the report.
Other Dismissal
In other cases, the small business employer must give the employee a reason why he or she is at risk of being dismissed. The reason must be a valid reason based on the employee’s conduct or capacity to do the job.
The employee must be warned verbally or preferably in writing, that he or she risks being dismissed if there is no improvement.
The small business employer must provide the employee with an opportunity to respond to the warning and give the employee a reasonable chance to rectify the problem, having regard to the employee’s response. Rectifying the problem might involve the employer providing additional training and ensuring the employee knows the employer’s job expectations.
Procedural Matters
In discussions with an employee in circumstances where dismissal is possible, the employee can have another person present to assist. However, the other person cannot be a lawyer acting in a professional capacity.
A small business employer will be required to provide evidence of compliance with the Code if the employee makes a claim for unfair dismissal to Fair Work Australia, including evidence that a warning has been given (except in cases of summary dismissal). Evidence may include a completed checklist, copies of written warning(s), a statement of termination or signed witness statements.
[81] I respectfully agree with Asbury C’s characterisation of the effect of the Code in context with the objects of the Act, which she referred to in Jarvis v Anderson Plumbing & Roofing Pty Limited, at par [9]:
[9] The provisions dealing with the Small Business Fair Dismissal Code must be viewed in the context of Part 3-2 of the Act, in which they are found. That Part has as its object, ensuring that a “fair go all round” is accorded to both the employer and the employee concerned: s.381(2). The effect of section 385(c) is to deprive a dismissed employee of access to relief that is otherwise generally available to dismissed employees on the ground that their dismissal is harsh, unjust or unreasonable, in circumstances where the employer is a small business and has complied with the Code. The further effect of the Code is that where misconduct is serious so that the provisions of the Code dealing with summary dismissal apply, the employee is not entitled to the other provisions of the Code dealing with elements of procedural fairness, including:
• The right to be given a valid reason why he or she is at risk of being dismissed;
• A warning that there is a risk of dismissal if there is no improvement;
• An opportunity to respond to the warning and a reasonable chance to rectify the problem, having regard to the response; and
• The choice to be represented in discussions in circumstance where dismissal is possible.
[82] The respondent argued that the applicant was dismissed for serious misconduct and consequently the notice and warning provisions of the Code did not apply. Of course, the applicant was not summarily dismissed, but dismissed with pay in lieu of notice. However, the fact that two weeks’ wages were paid in lieu of notice, does not detract from the common proposition, that an employee can be dismissed for misconduct and paid any amount in lieu of notice, or such other gratuity, as the employer might be minded to make. On one view, where there is payment in lieu of notice, as occurred here, means a dismissed employee receives payments to which he/she might not otherwise be entitled. There can be no basis for criticising an employer for doing so. Nevertheless, for the reasons I shall later develop, I accept that the applicant’s dismissal was for serious misconduct. Consequently, the provisions in the Code in respect to notice and warnings are not relevant. In any event, the applicant had received a warning in the 17 August 2010 letter and had, despite Ms Dabarera’s submission, been given an opportunity to improve her behaviour. While she was not at work after 17 August 2010, she was given an opportunity to improve her behaviour, namely, her attitude to Ms Corbett at the meeting on 2 September 2010. She not only squandered this opportunity, but reinforced her misconduct by referring again to Ms Corbett’s ‘mission management’ style. In my view, her subsequent written responses were argumentative, self-serving and offered not a skerrick of remorse for her unfounded allegations against Ms Corbett or the continued offensive reference to her ‘mission management’ style. As I said in Karen Albert v Techni-Clean Australia [2011] FWA 2665, the obvious reason why warnings are given are to hopefully stimulate a change in behaviour or conduct. From my reading of the applicant’s responses, there was little the applicant put which would give the respondent any encouragement or comfort that the applicant would alter her attitude to Ms Corbett if she was returned to the workplace. That the respondent was perfectly entitled to come to that conclusion was reinforced further by its own decision to ignore Ms Broadbent’s complaint in early 2010 and ‘put it behind them’. Despite this ‘olive branch’ the applicant’s antagonism towards Ms Corbett intensified.
[83] Ms Dabarera put that in the Code’s Checklist the respondent had said the applicant was dismissed, inter alia, for unwillingness to follow directions and bullying. As these two matters were not addressed in any of the correspondence from the respondent, then the applicant obviously had no opportunity to properly respond. In my view, Ms Dabarera places too much reliance on the Code’s Checklist and her assumptions about the significance of the Checklist are misconceived. It is no more, and no less, than what it says it is - a checklist. It is to assist a small business employer in properly dealing with the dismissal of an employee. Indeed, there is no requirement that the Checklist is to be provided to the dismissed employee. The critical documentation in this case, is the letter of 17 August 2010, the document provided in the 2 September 2010 meeting and the letter of termination. In any event, there can be no doubt that the applicant knew precisely what the reasons for her dismissal were. Even so, I agree with Mr Pomeroy that some of the applicant’s conduct could well be characterised as ‘bullying’. Given these circumstances, there can be no denial of procedural fairness arising from a distinction between what the notified reasons for dismissal were and what was written in the Checklist.
[84] In addition, I see no merit in Ms Dabarera’s submission that the applicant was given no opportunity to improve or correct her behaviour and, therefore, the respondent was in breach of the Code. In any event, a breach of the Code might not necessarily invalidate the respondent’s decision to dismiss the applicant. I need not develop this proposition any further, because, as I said before, the warning provisions of the Code were not applicable in this case.
[85] While the term ‘serious misconduct’ in the Code is not associated with the descriptor of ‘wilful’, wilful or deliberate behaviour is to be found as one of the definitions of serious misconduct in the Regulations to the Act. Regulation 1.07, is expressed as follows:
1.07 Meaning of serious misconduct
(1) For the definition of serious misconduct in section 12 of the Act, serious misconduct has its ordinary meaning.
(2) For subregulation (1), conduct that is serious misconduct includes both of the following:
(a) wilful or deliberate behaviour by an employee that is inconsistent with the continuation of the contract of employment;
(b) conduct that causes serious and imminent risk to:
(i) the health or safety of a person; or
(ii) the reputation, viability or profitability of the employer’s business.
(3) For subregulation (1), conduct that is serious misconduct includes each of the following:
(a) the employee, in the course of the employee’s employment, engaging in:
(i) theft; or
(ii) fraud; or
(iii) assault;
(b) the employee being intoxicated at work;
(c) the employee refusing to carry out a lawful and reasonable instruction that is consistent with the employee’s contract of employment.
[86] It seems tolerably clear that the respondent relies on 2(a) above which refers to ‘wilful or deliberate behaviour that is inconsistent with the continuation of the contract of employment’. Given this is also a commonly understood meaning of ‘serious misconduct’, I refer to what I said recently on this point in Siriwardana Dissanayake v Busways Blacktown Pty Ltd [2011] FWA 3549. At paras [88] to[ 92], I said:
[88] Did the serious misconduct here alleged by Busways constitute a wilful repudiation of the contract of employment by the applicant? In deliberating on this question, I refer to the following authorities:
[89] In North v Television Corporation Ltd (1976) 11 ALR 599, Franki J said at p 616:
“It is clear that a single act of disobedience may be sufficient to justify dismissal on the ground of misconduct but it was held in Laws v London Chronicle (Indicator Newspapers) Ltd [1959] 2 All ER 285, that to justify summary dismissal a single act must be such as to show that the employee was repudiating the contract of service or one of its essential conditions.”
[90] The 1959 English case referred to above makes it plain that an act of disobedience or misconduct (justifying dismissal) requires also that the disobedience must be ‘wilful’:
“... I do, however, think (following the passages which I have already cited) that one act of disobedience or misconduct can justify dismissal only if it is of a nature which goes to show (in effect) that the servant is repudiating the contract, or one of its essential conditions: and for that reason, therefore, I think that one finds in the passages which I have read that the disobedience must at least have the quality that it is “wilful”: it does (in other words) connote a deliberate flouting of the essential contractual conditions.”
[91] In Concut Pty Ltd v Worrell and Anor (2000) 103 IR 160, his Honour, McHugh J, dealt with the ordinary relationship of the employer and employee at common law as follows:
“The ordinary relationship of employer and employee at common law is one importing implied duties of loyalty, honesty, confidentiality and mutual trust. At common law:
“[c]conduct which in respect of important matters is incompatible with the fulfilment of an employee’s duty, or involves an opposition, or conflict between his interest and his duty to his employer, or impedes the faithful performance of his obligations, or is destructive of the necessary confidence between employer and employee, is a ground of dismissal. ...[T]he conduct of the employee must itself involve the incompatibility, conflict, or impediment, or be destructive of confidence. An actual repugnance between his acts and his relationship must be found. It is not enough that ground for uneasiness as to its future conduct arises.”
In the present case, the findings at trial went beyond mere uneasiness as to the future. They necessitated, or at least warranted, a conclusion that the “confidence” essential to the relationship of employer and employee had been destroyed. Instead of pursuing the interests of the company and its shareholders, the employee had pursued his own private interests. Not only was the employee in breach of his duty of fidelity and trust owed to the employer, he had remained in breach of that duty to the date of the trial. Until that time he had not accounted for the benefits wrongly appropriated by him. Indeed, he had denied any wrongful appropriation. The issue so tendered at the trial was determined against the employee. He was then subject to the employer’s counter-claim for an order to make a refund. Such order was duly made at trial. It was not contested on appeal. Given his senior status in the company’s service and the nature and extent of the misconduct disclosed in the evidence and accepted by the primary judge, it was open to him to find that the employee had undermined the confidence essential to the ongoing relationship of employment. Prima facie, this had afforded a legal justification for the employee’s summary dismissal.
It is, however, only in exceptional circumstances that an ordinary employer is entitled at common law to dismiss an employee summarily. Whatever the position may be in relation to isolated acts of negligence, incompetence or unsuitability, it cannot be disputed (statute or express contractual provision aside) that acts of dishonesty or similar conduct destructive of the mutual trust between the employer and employee, once discovered, ordinarily fall within the class of conduct which, without more, authorises summary dismissal. Exceptions to this general position may exist for trivial breaches of the express or implied terms of the contract of employment. Other exceptions may arise where the breaches are ancient in time and where they may have been waived in the past, although known to the employer. Some breaches may be judged irrelevant to the duties of the particular employee and an ongoing relationship with the employer. But these exceptional cases apart, the establishment of important, relevant instances of misconduct, such as dishonesty on the part of an employee like Mr Wells, will normally afford legal justification for summary dismissal. Such a case will be classified as amounting to a relevant repudiation or renunciation by the employee of the employment contract, thus warranting summary dismissal.”
[92] More recently a Full Bench of FWA considered whether a valid reason for summary dismissal (a consideration under s 387 of the Act) involves different considerations to dismissals on notice. In Magers v Commonwealth of Australia (Department of Health and Ageing) [2010] FWAFB 4385 (‘Magers’), the Full Bench said:
[10] It is well established that the requirement to consider whether a valid reason for a termination exists does not involve different considerations for summary terminations and terminations on notice. In a recent Full Bench decision it was said:
“[13] ... The approach to s 652(3)(a) and its predecessors in the context of summary dismissal has been well established in decisions of Full Benches of the Commission. In Annetta v Ansett Australia (Annetta) a Full Bench said:
“[9] It was submitted on behalf of the appellant that in cases of summary dismissal there can be no valid reason for the termination within the terms of s.170CG(3)(a) unless the employee is guilty of conduct justifying summary dismissal at common law. In this respect it was further submitted that the common law requirement goes beyond wilful disobedience in that the conduct must amount to a refusal to be bound by the terms of the contract: Adami v Maison de Luxe Limited (1924) 35 CLR 143. Mr Langmead submitted that the appellant's conduct on 17 February, 1998 could not be so regarded because there was no instruction given to the appellant, only a request, and the appellant provided an adequate explanation for not doing the work he was asked to do.
[10] We think there are a number of answers to this submission. It is generally accepted that the term "valid reason" should be construed to mean "sound, defensible or well-founded": Selvachandran v Peterson Plastics Pty Ltd (1995) 62 IR 371 at 373. Although that case concerned legislation which has now been repealed it is still regarded as authoritative. To limit the meaning of the term "valid reason" by importing a test amounting to repudiation of the contract at common law is unwarranted and impermissible. Secondly 170CG(3)(a) focuses on the reason for termination. The appellant's construction would result in an arbitrary application of the section in some circumstances. Take a case where an employee is guilty of conduct which does not amount to misconduct justifying summary termination. If the employer terminates the employment on notice there would be a valid reason for doing so. If the employer terminates the employment summarily there would not be a valid reason for doing so. The validity of the reason cannot be made to depend on whether or not the termination was on notice. Thirdly, however, we are not convinced that if the common law test were applied it would make any difference in this case. The Senior Deputy President found that the appellant had refused to do the duties he was requested to do and that the explanation he gave for the refusals was unreasonable. We think these findings were clearly open to her. The appellant did not say during the enquiry into his conduct that he was not given a direction. Furthermore he continued to maintain his right to refuse to do work which was not his and to refuse to rectify work which somebody else had performed unsatisfactorily. The appellant took this position in an interview more than a week after the day of the refusals. This amounts to the unilateral inclusion of a new term in the employment contract and by necessity amounts to a refusal to observe the fundamental requirement of any contract of service - to be ready, willing and available to carry out the lawful directions of the employer. In the circumstances we reject the submission that the Senior Deputy President should have found that there was no valid reason for the termination of the appellant's employment.”
[14] The decision in Annetta was approved by another Full Bench in Jupiters Limited trading as Conrad Jupiters Gold Coast v G Atfield where the Full Bench expressed the matter in the following terms:
“[19] Secondly, on one reading of the decision, the reasoning of the Commissioner appears to have imposed an obligation on the employer to prove “serious misconduct” sufficient to justify summary dismissal at common law as a prerequisite to establishing a valid reason within the meaning of s.170CG(3)(a). Such an approach, if adopted, would be incorrect. Proof of misconduct justifying summary dismissal at common law is a sufficient but not a necessary condition to establishing a valid reason within the meaning of s.170CG(3)(a). Nevertheless, since for the reasons we have given we have concluded that the termination of Mr Atfield’s employment was harsh, it is not necessary to take that matter further.”
(references omitted)
[15] The proposition was adopted and applied in other Full Bench decisions in Garry Robin v Worley ABB, Abdel-Karim Osman v Toyota Motor Corporation Australia Ltd (Osman) and Thomas Brian Potter v WorkCover Corporation. Those authorities are not inconsistent with the decision of Justice Jessup in Shanahan v Australian Industrial Relations Commission (No 2) where his Honour said:
“[75] There is no doubt but that, if wilfulness in the Laws sense was an essential ingredient of the university’s “valid reason” for terminating the employment of the applicant, the Full Bench would have constructively failed to exercise jurisdiction if, assuming that the matter had been properly put to it, it omitted to address that question. There is also no doubt but that, on the facts of this case, the majority of the Full Bench made no reference to Laws or to the principle for which it stands. I consider, however, that there is no substance in the submissions made on behalf of the applicant in this regard, for reasons which follow.
[76] First, neither the Commission at first instance nor the Full Bench on appeal was concerned with the question whether, as a matter of contract, the university was entitled lawfully to dismiss the applicant summarily. I accept, of course, that an answer to that question would often be (and in the present case might well have been) an ingredient in the series of propositions which together provide an answer to the question with which the Full Bench was concerned, namely, whether the university had a “valid reason” for the termination. But the question whether the applicant’s conduct was repudiatory was not, as such, the question which the Full Bench was required to address. It was not an essential statutory or legal ingredient, such that failure to take it into account would constitute a constructive failure to exercise jurisdiction.”
[16] In the circumstances of this matter the University purported to terminate Dr Asher’s employment for serious misconduct within the meaning of that term in the University’s enterprise agreement. If it successfully established that Dr Asher had engaged in serious misconduct it would necessarily follow that there was a valid reason for the dismissal. However, the converse is not true. As established by Annetta, the question that needed to be considered was whether there was a “valid reason” in the Selvachandran sense – whether the reason was sound, defensible or well founded. Whether it also amounted to serious misconduct may well be a factor relating to the overall characterisation of the termination but it was not an essential requirement in the determination of whether a valid reason exists.
[17] In our view, the question of whether a summary dismissal complies with an applicable enterprise agreement is a relevant consideration to the overall question of whether the termination is harsh, unjust or unreasonable and is best considered in this case in the catch all category of other relevant matters.
[18] We are concerned that the conclusions of the Commissioner in this matter equate the concepts of “serious misconduct” with a “valid reason”. Because she found that the conduct was misconduct falling short of the description of serious misconduct, the Commissioner concluded that there was no valid reason for the termination.
[19] This is an erroneous approach inconsistent with Full Bench authority. It was not argued before us that the Full Bench authority should not be followed. In our view it must be followed and applied in this case. This error alone is sufficient to find that the discretion vested in the Commissioner miscarried and the appeal should be upheld.” 2
(references omitted)
[11] These cases demonstrate that the existence of a valid reason does not depend on consistency with requirements for termination for other purposes such as the requirements of an enterprise agreement, legislation or the common law. A valid reason is one that is sound, defensible or well-founded. If a termination is inconsistent with some other obligation, that is a factor to be considered under other criteria relevant to the overall conclusion in the matter.
[12] On the basis of this line of authority the Commissioner would have fallen into error to do what counsel for Ms Magers said should have been his approach. There is no substance in this ground of appeal. Further, counsel for Ms Magers has not established that the Commissioner’s finding on the existence of a valid reason for the termination is in error.
[87] Turning now to the criteria for establishing whether the applicant’s dismissal was ‘harsh, unreasonable or unjust’, s 387 of the Act mandates the matters FWA is to have regard to in determining this question. These are:
(a) whether there was a valid reason for the dismissal related to the person’s capacity or conduct (including its effect on the safety and welfare of other employees); and
(b) whether the person was notified of that reason; and
(c) whether the person was given an opportunity to respond to any reason related to the capacity or conduct of the person; and
(d) any unreasonable refusal by the employer to allow the person to have a support person present to assist at any discussions relating to dismissal; and
(e) if the dismissal related to unsatisfactory performance by the person—whether the person had been warned about that unsatisfactory performance before the dismissal; and
(f) the degree to which the size of the employer’s enterprise would be likely to impact on the procedures followed in effecting the dismissal; and
(g) the degree to which the absence of dedicated human resource management specialists or expertise in the enterprise would be likely to impact on the procedures followed in effecting the dismissal; and
(h) any other matters that FWA considers relevant.
[88] The frequently quoted authority as to the meaning of ‘harsh, unjust and unreasonable’ in an industrial context, is that of the High Court in Byrne & Frew v Australian Airlines Ltd (1995) 185 CLR 410, where McHugh and Gummow JJ said:
“It may be that the termination is harsh but not unjust or unreasonable, unjust but not harsh or unreasonable, or unreasonable but not harsh or unjust. In many cases the concepts will overlap. Thus, the one termination of employment may be unjust because the employee was not guilty of the misconduct on which the employer acted, may be unreasonable because it was decided upon inferences which could not reasonably have been drawn from the material before the employer, and may be harsh in its consequences for the personal and economic situation of the employee or because it is disproportionate to the gravity of the misconduct in respect of which the employer acted”.
[89] The Full Bench in Magers above (par [13]) cited with approval the meaning of ‘valid reason’ as expressed by North J in Selvachandran v Peterson Plastics Pty Ltd, at 373:
“In its context in s.170DE(1), the adjective “valid” should be given the meaning of sound, defensible or well founded. A reason which is capricious, fanciful, spiteful or prejudiced could never be a valid reason for the purposes of s.170DE(1). At the same time the reasons must be valid in the context of the employee’s capacity or conduct or based upon the operational requirements of the employer’s business. Further, in considering whether a reason is valid, it must be remembered that the requirement applies in the practical sphere of the relationship between an employer and an employee where each has rights and privileges and duties and obligations conferred and imposed on them. The provisions must “be applied in a practical, commonsense way to ensure that the employer and employee are treated fairly”.
[90] Ms Dabarera raised a number of matters which, she submitted, had demonstrated that the applicant was denied procedural fairness. Subclauses (b), (c), (d) and (e) of s 387 of the Act relevantly deal with issues surrounding procedural fairness when an employer dismisses an employee. The High Court in Byrne & Frew v Australian Airlines Ltd spoke of ‘unfair procedures’ being ‘arbitrary, irrational or unreasonable’ when it said:
“The distinction between procedure and substance is elusive. This is so even in those fields of private international law, the statute law dealing with limitations of actions and the effect of repeal upon accrued rights, and the Statute of Frauds, where it has an entrenched operation. In our view, it is unhelpful and contrary to the tenor of the Award to introduce it into cl 11(a).
That is not to say that the steps taken, or not taken, before termination may not in a given case be relevant to consideration of whether the state of affairs that was produced was harsh, unjust or unreasonable. Thus, it has been said that a decision which is the product of unfair procedures may be arbitrary, irrational or unreasonable. But the question under cl 11(a) is whether, in all the circumstances, the termination of employment disobeyed the injunction that it not be harsh, unjust or unreasonable. That is not answered by imposing a disjunction between procedure and substance. It is important that matters not be decided simply by looking to the first issue before there is seen to be any need to enter upon the second.”
[91] Moore J said in Wadey v YMCA Canberra [1996] IRCA 568, 12 November 1996, that an employee has a right to know the nature of the allegations being made and have an opportunity to defend him or herself:
“In my opinion the obligation imposed on an employer by that section has, for present purposes, two relevant aspects. The first is that the employee must be made aware of allegations concerning the employee's conduct so as to be able to respond to them. The second is that the employee must be given an opportunity to defend himself or herself. The second aspect, the opportunity to defend, implies an opportunity that might result in the employer deciding not to terminate the employment if the defence is of substance. An employer may simply go through the motions of giving the employee an opportunity to deal with allegations concerning conduct when, in substance, a firm decision to terminate had already been made which would be adhered to irrespective of anything the employee might say in his or her defence. That, in my opinion, does not constitute an opportunity to defend.”
[92] However, two other questions arise in circumstances where procedural faults are established; firstly, did the seriousness of the misconduct outweigh any procedural faults and, secondly, would the procedural faults have affected or altered the ultimate outcome of dismissal? In this respect, I refer to what I recently said in Batterham and others v Dairy Farmers Ltd t/a Dairy Farmers [2011] FWA 1230, at par 274:
“Nevertheless, it must be steadily borne in mind that not all procedural defects, either singularly, or in combination, will result in the Tribunal finding that a particular dismissal is procedurally ‘harsh, unreasonable or unjust’. Put another way, the seriousness of the proven misconduct will not always be outweighed by any identified procedural fault/s. In this respect, I refer to a decision of the Full Bench of the AIRC in Farquharson v Qantas Airways Limited [2006] AIRC 488 at par [41]:
[41] The fact of unfairness in the employer’s decision making process, even if it involves a breach of a term in a certified agreement, is but a factor to be taken into account in determining whether a termination of employment was harsh, unjust or unreasonable. In circumstances where, as here, the merits of a termination of employment based on misconduct have been the subject of a full hearing in the Commission (in which the employer must establish the alleged misconduct on the balance of probabilities) and the dismissal has been found to be justified, it will be rare for a defect in an internal disciplinary process that preceded the termination justifying a conclusion that the termination was harsh, unjust or unreasonable. This is so because, almost invariably in such circumstances, it may be inferred that the outcome of the disciplinary process would have been the same even if there had been no such defect.”
[93] I would also respectfully adopt the views of Lacey SDP in De Silva v Exxon Mobil Australia Pty Ltd [PR910623], where his Honour said at par [75]:
“Affording employees procedural fairness in relation to a termination will be relevant in establishing whether or not a termination is harsh, unjust or unreasonable. However, as procedural fairness is to be only one factor to be considered along with other relevant factors, the intention is that undue weight will not be given to procedural defects in a termination (my emphasis)”
[94] Another important consideration arises in cases of unfair dismissals under the Act. This is the principle found at s 381(2) of the Act, as follows:
(2) The procedures and remedies referred to in paragraphs (1)(b) and (c), and the manner of deciding on and working out such remedies, are intended to ensure that a “fair go all round” is accorded to both the employer and employee concerned.
[95] Ms Dabarera relied on the decision of Rapp v Wauhope RSL Club Ltd. There are no similarities in the facts and circumstances in Rapp to the facts and circumstances of this case. Mr Rapp was never informed of the complaints made against him or their terms and was never asked to respond to the complaints before he was dismissed. That is not the position here. (Similarly with the decision of Johnson v Catholic Education Office, Diocese of Parramatta [1998] NSWIRComm 446.)
The real issue
[96] In my opinion, this case represents a classic illustration of a disgruntled employee who, having missed out on a promotional opportunity, then seeks to unreasonably and vindictively undermine the successful candidate. What usually follows is that the disgruntled employee’s manifestation of unhappiness turns into a campaign of resistance against the employer and petty nitpicking about insignificant matters. Ultimately, of course, the outcome of these distractions is a failure of performance or, more seriously, allegations of misconduct against the disgruntled employee. That said, I have no doubt that the applicant was very unhappy and resented not being appointed to the Acting Co-ordinator’s position. That this was so is no more aptly demonstrated than when she told Ms de Costa that she might not be around when she returned from long service leave. Her attitude and conduct towards Ms Corbett was entirely consistent with this resentment. Nevertheless, her conduct was a completely unreasonable and unnecessary reaction which, in hindsight, was most unwise.
[97] In addition, I do not accept that it was reasonable for the applicant to be upset about the referee issue or the unsigned letter of complaint. Firstly, given that the withdrawal of Mr Allen from being her referee (which was entirely appropriate in the circumstances) was a matter completely beyond the respondent’s control, it was unreasonable and illogical for her to blame the respondent for Mr Allen’s withdrawal. In any event, I fail to see how the withdrawal of a referee for a job application, amounts to unfair treatment or disadvantage. It was a very long bow to draw. Secondly, on the applicant’s own evidence, the unsigned complaint was not pursued by the respondent after 4 June 2010. She agreed Ms de Costa had said ‘Let’s put it behind us and have a fresh start’. In these circumstances, I do not understand how it remained an issue for the applicant subsequently.
Findings on the evidence
[98] Much of the evidence in this matter was uncontested. However, where the applicant’s evidence differs from that of Ms de Costa and Ms Corbett’s, it is their evidence which I prefer. Specifically, I accept:
• the applicant had told Ms de Costa ‘I may not be here (or don’t be surprised if I’m gone) when you return from long service leave’;
• the applicant followed Ms Corbett around the office in an attempt to intimidate her;
• the applicant well knew that Ms Corbett was offended by her use of the term ‘mission manager’;
• the 2 September 2010 letter did not contain new allegations to those of the disciplinary letter of 17 August 2010;
• Ms de Costa had not said at the 2 September 2010 meeting ‘this was the end of the matter’. Such a comment is entirely at odds with the fact that the applicant was invited to respond two further times to the allegations and did so. If this was the end of the matter, the applicant would have been dismissed at that meeting;
• the 2 September 2010 meeting was never accepted by the respondent as a mediation meeting. The applicant and her Union would have been under no illusions that it was a disciplinary meeting;
• Ms Corbett had nothing to do with the decision to dismiss the applicant and had never recommended such a decision. It was a figment of the applicant’s imagination;
• given the applicant’s admitted conduct and attitude towards Ms Corbett, it is ridiculous to suggest that her relationship with Ms de Costa had anything to do with the applicant’s misconduct and subsequent dismissal;
• Mr Allen’s decision to withdraw as the applicant’s referee had nothing to do with the respondent; and
• Ms Corbett did not deliberately interrupt or interfere with the applicant’s work, noting that the office is an ‘open plan’.
[99] Further, I do not accept that the applicant was recommended by Ms Broadbent to Ms de Costa for the position of Acting Co-ordinator. Both Ms de Costa and Ms Corbett denied she did so. Given Ms Broadbent’s criticisms of the applicant (which I accept were untested in an evidentiary sense), it is difficult to reconcile Ms Broadbent doing so. It makes no sense. In any event, not much turns on this evidence.
Reasons for dismissal
[100] There can be little doubt that the applicant’s use of the term ‘mission manager’ to describe Ms Corbett was the highest form of derision, hurt and offence for any person. I accept Mr Rowse’s expert evidence, that given the historical context from which the term derived, ‘mission manager,’ when used by an Aboriginal person, is plainly intended to have a negative connotation. In my view, the applicant’s intentions were perfectly clear. She had intended to be hurtful and offensive when she used this expression. Had the term only been used once in the ‘heat of the moment’, one might give the applicant the benefit of the doubt. However, given it was stated more than once, even after she claimed to have apologised to Ms Corbett for doing so, I cannot accept the applicant was genuinely contrite about the comment. Moreover, I do not accept that the applicant was genuinely sorry for using the term in respect to Ms Corbett. On her own evidence, she had apologised if she had offended Ms Corbett. This was not an apology for using the expression, but an apology if Ms Corbett was offended by it. Her so-called apology could only be described as weak and disingenuous.
[101] In addition to using the term ‘mission manager’ three times to describe Ms Corbett, the applicant was dismissed for a range of other reasons; including:
• implying that Ms Corbett had improperly approved the purchase of Apple computers from a friend of hers;
• telling Ms Corbett she was ‘unprofessional and unqualified’;
• wrongly accusing her of misusing the respondent’s vehicle and petrol card;
• accusing Ms Corbett of taking the vehicle log book home to change the entries in order to cover up the personal use of the vehicle;
• demanding Ms Corbett take the minutes in long hand;
• telling Ms Corbett she had no right to get the Acting Co-ordinator’s job;
• wrongly believing the Co-ordinator’s role was an Aboriginal designated position and Ms Corbett was therefore unfit for the job;
• accusing Ms Corbett of manipulating the Acting Co-ordinator’s position for her own benefit;
• accusing Ms Corbett of typing up her own letter of appointment;
• accusing Ms Corbett of ‘dictating’ to her; and
• accusing Ms Corbett of not following the respondent’s policies and procedures.
[102] Given this level of hostility and disrespect from a subordinate, it is unsurprising that Ms Corbett felt stressed and anxious about her work and needed time off. This was not just a case of an employee exercising her rights at the workplace or holding strong independent views, contrary to those of management. In my assessment, there was no legitimacy to any of the applicant’s complaints against Ms Corbett. This is so for the following reasons:
[103] Firstly, a failure by Ms Corbett to take minutes in long hand was not only a piddling and impertinent complaint, but was entirely misguided and stupid.
[104] Secondly, the applicant was impertinent and disrespectful when she queried Ms Corbett’s use of the work vehicle and petrol card, particularly given her knowledge of Ms Corbett’s right to use the vehicle for personal reasons. This was an undeserving and improper accusation against Ms Corbett. It is little wonder Ms Corbett took offence to an accusation of what amounted to corrupt conduct.
[105] Thirdly, the applicant accused Ms Corbett of impropriety in respect to the purchase of Apple computers from a friend of hers. There was not a scrap of evidence to support this claim. Her belief was based on nothing more than her own vindictiveness and determination to make any allegation against Ms Corbett no matter how fanciful, hurtful or absurd.
[106] In my view, the applicant’s campaign against Ms Corbett was deplorable and utterly unjustified. She should be ashamed of herself. Her behaviour and conduct towards her supervisor was unacceptable and intolerable. It amounted to serious misconduct. In these circumstances, I am satisfied that the Code’s procedures did not apply and, further, that the applicant’s misconduct amounted to a valid reason for her dismissal. Moreover, I am comfortably satisfied that the applicant’s ongoing conduct was inconsistent with the continuation of the contract of employment. (see para 86 above)
Procedural Issues
[107] As to the claims of procedural unfairness, I do not accept that the respondent raised new allegations against the applicant at the meeting on 2 September 2010. An objective reading of the 17 August 2010 letter and the letter given to her at the meeting, reveals an entirely consistent set of related events, about which the applicant would have been fully aware. Indeed, she responded in some detail to all of the allegations, without making any concessions or admissions. It is important not to lose sight of the fact that the applicant responded to all of the issues raised by the respondent in both its letters of 17 August 2010, and in the meeting of 2 September 2010. Indeed, she did so in scrupulous detail, not once, but twice after the 2 September 2010 meeting and with the support of her Union. Given these facts, it is difficult to sustain an argument that the applicant’s dismissal involved a denial of procedural fairness or a denial of natural justice.
[108] The applicant criticised the respondent for the delay in handling and concluding the issues resulting in her dismissal. Putting aside Ms Broadbent’s complaint, which ultimately was not taken into account by the respondent, the disciplinary process effectively commenced on 17 August 2010, when she was suspended and informed of the allegations. The date of dismissal was 5 November 2010. Objectively, this time period might seem excessive. However, a number of factors contributed to the delay:
• Ms de Costa’s absence on long service leave. She was the only person who could make decisions of this kind;
• the abandonment of the 25 August 2010 disciplinary meeting;
• the Union’s acknowledged contribution to the delay; and
• the fact Ms de Costa was running a small organisation with a heavy workload and her own health issues.
[109] Notwithstanding the delay, the applicant was on full pay during the entire period and therefore suffered no financial detriment. While I accept the matter should have been resolved in a more timely fashion, I do not consider, given the above factors, that the Union has established any procedural faults of such significance as to have affected the outcome of the disciplinary process or which resulted in the applicant having suffered an incurable injustice.
CONCLUSIONS
[110] Earlier I found that there was a valid reason/s for the applicant’s dismissal; she was notified of the reason/s in the letter of 17 August 2010, and in the meeting of 2 September 2010; and she was given three opportunities to respond to the allegations and she did so. Accordingly, I am satisfied that s 387(a), (b) and (c) have been met. The applicant was represented by her Union, in accordance with the Union’s own protocols in respect to such matters and the Union responded on her behalf and attended the meeting on 2 September 2010, (s 387(d)).
[111] Subsection (e) of s 387, is not relevant to this matter although it might be observed that the applicant had clear warning of her behaviour in the letter of 17 August 2010. Although the respondent is a small employer, I do not find cause for any serious criticism of its procedures in handling the matter, save perhaps for the delay in finalising it, which I have already commented on (s 387(f)). Any lack of finesse in process or procedure in respect to the applicant’s dismissal must be seen in light of the respondent’s lack of human resource expertise and the fact that Ms de Costa undertook this role in addition to all of her other managerial and supervisory duties. I have taken this matter into account.
[112] Finally, I have earlier raised a number of matters I consider relevant to this matter, primarily that it involved the misguided and improper actions of a disgruntled employee who had missed out on a promotional opportunity. Additionally, I have also had regard to the applicant’s relatively short service (January 2009 to November 2010), the extent and nature of the applicant’s skills and expertise and the fact that she had done little to mitigate her loss, having made only one job application between her dismissal on 5 November 2010, and the date of the arbitration (5 April 2011).
[113] For all the aforementioned reasons, I find that the applicant’s dismissal on 5 November 2010, was neither ‘harsh, unreasonable or unjust’ within the meaning of s 387 of the Act. Accordingly, her application for an unfair dismissal remedy must be dismissed. An order to that effect will be published separately to this decision.
DEPUTY PRESIDENT
Appearances:
Ms N Dabarera, Assistant Industrial Officer, United Services Union, for the applicant
Mr J Pomeroy, Solicitor, Gilbert + Tobin Lawyers, for the respondent
Hearing details:
2011
SYDNEY
5 April
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