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[2004] VSCA 90
Court of Appeal (Vic)
2004-05-21
ORMISTON, BUCHANAN and EAMES, JJ.A.
Original judgment source is linked above.
[ 2004] VSCA 90
Contract - Wrongful dismissal - Summary dismissal for misconduct - Employee has no right to be heard - Employer's obligation of good faith not breached by summary dismissal for cause of an unwanted employee.
respondent as an employee. Statutory and award-based regimes may now require some such notice where employers are bound by such regimes, and that may be seen generally as being desirable when applied to the particular employment relationships which are made subject to the terms of those regimes. At common law, however, the right to determine a contract and thereafter to justify it on grounds not raised or even known at the time has long been recognised: see, e.g., Shepherd v. Felt & Textiles of Australia Ltd.[1], as discussed and referred to on many subsequent occasions, including in Concut Pty. Ltd. v. Worrell[2], applying it in the context of an employment contract. Affording an opportunity to be heard may well be a courtesy extended to employees in certain circumstances, but, in the absence of some specific stipulation requiring it, such a term is not ordinarily to be implied. To dismiss an employee, the circumstances must always show that the particular employee no longer intends to be bound by the essential terms of the employment contract, but there may be many reasons why immediate dismissal without making further enquiry of the employee may be the only appropriate course. Good relationships between members of staff are essential to any well run business, and enquiry into circumstances of the kind here alleged may unnecessarily create or exacerbate tensions. The right balance is a matter for the employer, indeed common sense frequently would dictate some checking of a person's allegations, but necessarily the employer must have good and proper grounds for terminating the employment.
manager operations of the appellants, a group of companies in the business of manufacturing pipelines. On 19 April 2001, the respondent's employment was summarily terminated. In these proceedings, the respondent has alleged that he was entitled to notice of his dismissal and has claimed damages for breach of contract.
"I am very sceptical of the notion that it contained any sexual invitation at all, and if it were to be interpreted in that fashion, it could not possibly be imagined to be anything more than a crude joke .... The situation that my mind is left in, however, is that I am not satisfied at all that what was said had a sexual connotation to it."
"The incident, if it occurred, and I assume for the purpose of this ruling that the lady was not making up what she said she heard, may have been misunderstood, but it did not contain any connotation of harassment of her, except in the most indirect fashion and it was not meant for her ears anyway."
"The conclusion I reach, therefore, is that the facts, if known at the time, would have and should have led to the matter being investigated. They would not, in fairness, be used as summary dismissal without requiring an explanation from the supposed wrongdoer. When the supposed wrongdoer did inquire about what he was being accused of at the time of dismissal, reliant upon other facts, Mr Boegel replied, `Sexual harassment and insubordination.'"
"I believe that this somewhat strange handling of the situation by Mr Mika subsequently, in alleging he heard what he said he heard, but then refusing to identify the person to whom the invitation was given, and those very stances he took up with Mr Paterson and with Mr Boegel leave me wondering what it was that Mr Mika was trying to achieve. ... I do not understand why he behaved in the way he did in relation to making the accusation but then not revealing the full particulars of it."
The second so-called irrelevant consideration was that the respondent was denied an opportunity to counter the charge.
"At common law a master is not bound to hear his servant before he dismisses him. He can act unreasonably or capriciously if he so chooses but the dismissal is valid. The servant has no remedy unless the dismissal is in breach of contract and then the servant's only remedy is damages for breach of contract."[4]
"Accusations of the sort that she made, in circumstances which apply here, would, in my view, certainly not, if I was the tribunal of fact, amount to evidence which would be sufficient to convict [the respondent] of an indecent assault. The conclusion I reach, therefore, is that the facts, if known at the time, would have and should have led to the matter being vitiated."
"Mr Boegel ... made the frank admission that he had formed the opinion ... that [the respondent] was no asset to the company, and that his engagement to work in a responsible position was a mistake, and he was looking for a way to terminate his employment. When it came to hand, in the form of the accusation that Mr Mika eventually made known, Mr Boegel seized the moment and dismissed him summarily when, in my view, he was not entitled to do so."
dismiss an employee when the employer wishes to dismiss the employee for reasons that have nothing to do with those facts. The duty of good faith does not qualify an employer's right to summarily dismiss an employee for misconduct.[6]
case law being replete with discussions as to the respective positions of "masters" and "servants"[8]. The principles stated by Lord Reid in that case, as discussed in the judgment of Buchanan, J.A., are now entrenched, and have only been overcome by statutory reform. In this case, however, the income level of the respondent denied to him such processes of procedural fairness as may have been applicable to his situation had the Workplace Relations Act 1996[9] applied.
[3] Ridge v. Baldwin [1963] UKHL 2; [1964] A.C. 40; Cooper v. Wilson [1937] 2 K.B. 309; Chief Constable of North Wales Police v. Evans [1982] UKHL 10; [1982] 1 W.L.R. 1155.
[4] [1971] 1 W.L.R. 1578 at 1581. See also Ridge v. Baldwin above at 64-66 per Lord Reid; McClory v. Post Office [1993] 1 All E.R. 457 at 462-3 per David Neuberger, Q.C.; Johnson v. Unisys Ltd. [2001] UKHL 13; [2001] 2 All E.R. 801 at 817 per Lord Hoffman and at 823 per Lord Millett; Byrne v. Australian Airlines Ltd. [1995] HCA 24; (1995) 185 C.L.R. 410 at 443 per McHugh and Gummow, JJ.; Coutts v. The Commonwealth [1985] HCA 40; (1985) 157 C.L.R. 91 at 121 per Dawson, J.; Sanders v. Snell (1998) 196 C.L.R. 329 at 352 per Callinan, J.; Brophy v. Mapstone [1984] FCA 257; (1984) 56 A.L.R. 135 at 142-3 per Smithers, A.C.J., Keely and Morling, JJ.
[5] Briginshaw v. Briginshaw [1938] HCA 34; (1938) 60 C.L.R. 336.
[6] Cf. Aldersea v. Public Transport Corporation [2001] VSC 169; (2001) 3 V.R. 499.
[7] [1971] 1 W.L.R. 1578, at 1581. I am not to be taken as suggesting that the conduct of the appellant was unreasonable or capricious. That question does not arise on this appeal.
[8] In Bell v Lever Brothers Ltd [1931] UKHL 2; [1932] AC 161, at 228, Lord Atkin illustrated his discussion of the question whether an employee was obliged to disclose to his employer his past faults by using the example of a man dealing with his butler, wine merchant and cook.
[9] See s.170CC(3) and Reg 30BB, Workplace Relations Regulations.
[13] [1985] 2 NZLR 378, at 383.
[14] [1995] HCA 24; (1995) 185 C.L.R. 410, at 443.
[15] [1963] UKHL 2; [1964] A.C. 40, at 65.
Intico (Vic) Pty Ltd & Ors
Walmsley [2004] VSCA 90