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[2001] VSC 194
Supreme Court of Victoria
2001-06-25
Ashley J
Original judgment source is linked above.
Tort - labour hire company - employee hired out to a third party - negligent conduct of employee causing damage to property of third party - whether labour hire company vicariously liable to third party for tortious conduct of employee - whether employee the servant pro hac vice of the third party - principles - whether employee entitled to claim protection of s. 66, Insurance Contracts Act 1984 (Cth). Contract - labour hire company - whether contract was to provide a man to third party, or was a contract to provide services of a particular kind - implication of terms into contract - whether warranty imposed by operation of s. 74(1) Trade Practice Act 1974 (Cth) - whether breach of contract.
The Plaintiff's claim against Skilled: the pleadings analysed; some conclusions
"I do not see how the [general employer] could escape liability. For the obligation to supply a crane and a man to work it is an obligation to supply a crane which is not defective and a man who is competent to work it."[3]
I should add one further remark concerning the implied term now under discussion. To my mind it is immaterial to determination whether the term should be implied whether Mr Sutton was, in performing his work at Deutz, for all purposes the employer of Skilled; or whether Skilled was then his general employer he then being a servant pro hac vice of Deutz. The contractual term would be relevant to adjustment of loss between Deutz and Skilled in either circumstance.
[diamond] occurred whilst the second defendant was performing the usual work tasks of a qualified forklift driver;
[diamond] "was caused by negligence of the second defendant and because he did not meet the reasonable competence of a qualified forklift driver";
[diamond] occurred by reason of breach of the term implied by s. 74(1).
Skilled denies breach. It goes on to allege further contractual terms to which I shall advert a little later.
"(a) provide the secondnamed defendant with a safe place of work; (b) instruct the secondnamed defendant in the safe method of the performance of his duties; (c) supervise the duties performed by the secondnamed defendant in an appropriate manner; (d) provide the secondnamed defendant with safe plant and equipment in order to perform his duties."
It contends that the plaintiff breached those terms, that such breach was the cause of the plaintiff's loss and damage, and alternatively that such loss and damage was contributed to by the breach.
The Plaintiff's claim against the Second Defendant: the pleadings analysed
"That conception is a very useful device to put liability on the shoulders of the one who should properly bear it, but it does not affect the contract of service itself. No contract of service can be transferred from one employer to another without the servant's consent: and this consent is not to be raised by operation of law but only by the real consent in fact of the man express or implied: see Nokes v Doncaster Amalgamated Collieries Ltd [1940] AC 1014. In none of the transfer cases which have been cited to us had the consent of the man been sought or obtained. The general employer has simply told him to go and do some particular work for the temporary employer and he has gone. The supposed transfer, when it takes place, is nothing more than a device - a very convenient and just device, mark you - to put liability on to the temporary employer; and even this device has in recent years been very much restricted in its operation. It only applies when the servant is transferred so completely that the temporary employer has the right to dictate, not only what the servant is to do, but also how he is to it: see Mersey Docks and Harbour Board v Coggins & Griffith (Liverpool) Ltd [1947] AC 1. Such a transfer rarely takes place, if ever, when a man is lent with a machine, such as a crane or a lorry: nor when a skilled man is lent so as to exercise his skill for the temporary employer. In such case the parties do not contemplate that the temporary employer shall tell the man how to manipulate his machine or to exercise his skill. But a transfer does sometimes take place in the case when an unskilled man is lent to help with labouring work: See Garrard v A.E. Southey & Co [1952] 2 QB 174; [1952] 1 TLR 630; [1952] 1 All ER 597."[17]
"Servants cannot be transferred from one service to another without their consent and even where consent may be implied there will always remain a question as to the extent and effect of the transfer."[19]
"In determining this question it has to be borne in mind that the employee's position is an important consideration. A contract of service is made between master and man and an arrangement for the transfer of his services from one master to another can only be effected with the employee's consent, express or implied. His position is determined by his contract. No doubt by finding out what his work is and how he does it and how he fulfils the task when put to carry out the requirements of an employer other than his own, one may go some way towards determining the capacity in which he acts, but a change of employer must always be proved in some way, not presumed. The need for a careful consideration of the circumstances said to bring about the change of employment has latterly been accentuated by the statutory provisions now in force for compulsory health and accident insurance and, in the case of many firms, by the existence of funds accumulated under a trust for the benefit of employees who will not lightly incur the risk of losing such benefits by a transfer of their services from one master to another."
"The rule to be derived from Mersey Docks and McDonald is not that two persons cannot be vicariously liable for the same damage or that an employee cannot be the servant of two masters, but that two employers of the same servant who negligently causes damage will not both be liable for the damage if one rather than the other has what Jordan C.J. called `the relevant control': McDonald.[25]
[diamond] Where the hirer can direct not only what the workman is to do, but how he is to do it[34].
[diamond] Where the hirer "is entitled to tell the employee the way in which he is to do the work[35].
[diamond] Where the complete dominion and custody over the servant has passed from the one to the other[36].
[diamond] Where, by an agreement "the employer vests in the third party complete, or substantially complete, control of the employee, so that he is not only entitled to direct the employee what he is to do, but how he is to do it"[37].
[diamond] Where it can be said that the hirer has such authority to control the manner in which the worker does his work that it can be said that the worker is serving the hirer, not merely serving the interests of the hirer[38].
[diamond] Where it cannot be said that the reason that the worker subjected himself to control of the so-called temporary employer as to what he did and how he did it was that his general employer told him to do so[39].
[diamond] Where it can be said that the servant was transferred, not merely the use and benefit of his work[40].
Was the second defendant the servant of pro hac vice of the plaintiff?
[1] A dichotomy which is pointed up by the different language of paragraphs 4 and 7 of the statement of claim; and which appears elsewhere in that document.
[6] The meaning of s. 74(3)(a) was discussed, with different approaches but the same outcome, in Wallis v Downard-Pickford (North Queensland) Pty Ltd [1994] HCA 17; (1994) 179 CLR 388.
[9] [1999] HCA 12; (1999) 197 CLR 61 at para. 27 and 28.
[10] Supra, at 396-397 per Toohey and Gaudron JJ.
[11] See paragraphs 85 and 86 in the majority judgment.
[13] See the evidence of Mr Cutchel at T.59-60.
[14] T. 150, lines 11-15, T. 151, lines 16-28.
[15] [1964] 3 All ER 18 at 20.
[18] [1986] VicRp 80; [1986] VR 831 at 836.
[20] (1999) 74 SASR 438 at 433.
[22] (1985) 3 ANZ Insurance Cases 60-631 at 78, 879.
[26] Discussed at length in Stevens v Brodribb Sawmilling Co Pty Ltd (1986) 160 CLR 16; see also Building Workers Industrial Union of Australia and Ors v Odco Pty Ltd [1991] FCA 87; (1991) 29 FCR 104 at 123-127.
[27] See Kondis v State Transport Authority [1984] HCA 61; (1984) 154 CLR 672.
[28] Although the observations concerning servant transfer made by Brennan J in that case at 692 are of relevance.
[29] Mercy Docks per Lord Simon at 10; see also Oceanic Crest at 646 per Wilson J.
[30] Mersey Docks per Lord Porter at 17; and probably also where the general employer provides a skilled worker.
[31] Savory at 20 per Denning MR; Denham at 414 per Denning MR.
[32] Donovan v Laing, Wharton & Down Construction Syndicate Ltd [1893] 1 QB 629 at 632 per Lord Esher MR.
[33] Mersey Docks per Lord Porter at 15 and Lord Uthwatt at 22.
[34] Mersey Docks per Lord Simonds at 18.
[35] Mersey Docks per Lord Porter at 17.
[36] Mersey Docks per Lord Simonds at 20. See also Bhoomidas v Port of Singapore Authority [1978] 1 WLR 189 particularly at 193 A-B and 194C.
[38] Paraphrasing Lord Uthwatt in Mersey Docks at 21.
[39] Paraphrasing Romer LJ in Denham at 446.
[40] Paraphrasing Bowen LJ in Moore v Palmer (1886) 2 TLR 781 at 782.
[41] See, as an example of the former approach, Bhoomidas. See also, for example, Garrard v A.E. Southey & Co and Anor [1952] 2 QB 174 at 176, 179. Parker J doubted, at 179, whether the test should be the same; but he nonetheless applied Mersey Docks. See further Opresnik v JC Smale & Co and Anor, Crockett J, unreported, judgment on third party proceedings delivered 15 November 1973. Contrast the observations of Diplock LJ in Savory at 21I-22D. Again, in Fennell v Supervision & Engineering Services Holdings Pty Ltd and Anor (1988) 47 SASR 6 at 10 Jacobs J pointed out that the hirer's liability, not in issue on the appeal, did not depend on it having become the temporary employer.
[42] See, for example, Mason & Cox at 443 per Doyle CJ.
[43] Mersey Docks and Bhoomidas are examples.
[44] Fennell was, apparently, such a case.
[45] Examples are BWIU v Odco, Accident Compensation Commission v Odco Pty Ltd (1990) 64 ALJR 607 and Mason & Cox.
[46] I think it was common ground that this was so in the case of first defendant. There was, in any event, evidence tending to that conclusion.
[47] Mr Syrett used the word "assignment".
[50] [1984] HCA 60; (1984) 155 CLR 306 at 311-313.
[51] [1986] HCA 20; (1986) 160 CLR 301 at 310-311.
[53] [1989] HCA 29; (1989) 167 CLR 78 at 90.
Deutz Australia Pty Ltd
Skilled Engineering Ltd [2001] VSC 194
(1994) 179 CLR 388
(1999) 197 CLR 1
(1999) 197 CLR 61
(1999) 74 SASR 438
(1986) 160 CLR 626
(1986) 160 CLR 16
(1991) 29 FCR 104
(1984) 154 CLR 672
(1988) 47 SASR 6
(1990) 64 ALJR 607
(1981) 55 ALJR 668
(1984) 155 CLR 306
(1986) 160 CLR 301
(1987) 163 CLR 611
(1989) 167 CLR 78