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[2001] VSCA 247
Court of Appeal (Vic)
2001-12-21
BROOKING, ORMISTON and CHERNOV, JJ.A.
Original judgment source is linked above.
[ 2001] VSCA 247
DISCRIMINATION - Equal opportunity - Direct discrimination in employment context by reason of a characteristic which is race or religion based - True reason for non-renewal of employment contract was employee's work capacity, but not a raced based characteristic - Whether the discriminator's reason for impugned conduct was race or religion related - Whether personality trait could be a characteristic - Whether sufficient evidence available for remission back to the Tribunal for re-hearing - Equal Opportunity Act 1984, s.17(4)(a); Equal Opportunity Act 1995 s.7(2)(b).
refusing, in early 1996, to renew her contract of employment. I will deal later with the comprehensive reasons of the Tribunal but, for the present, it is sufficient to note that it awarded her compensation for loss of income in the sum of $84,984.44, general damages in the sum of $10,000 and aggravated damages in the sum of $7,000. Further orders were made directing that certain documents be removed from the appellant's personnel file and that the first and second respondents provide a written apology to the appellant.
Relationship between the second respondent and the appellant: the Flinders Island trip
- inhibited the appellant bringing her daughter on to university premises
- made critical comments about the fact that she wore a national dress, was a vegetarian and abstained from drinking alcohol
- together with the third respondent was complicit in fabricating a series of complaints about the appellant to ensure that, on the expiration of her contract, she would not be reappointed to the MOSA program
- "victimised" the appellant in the sense of singling her out for unfair treatment.
(i) she was put through an ordeal in the form of a meeting at which she was confronted with allegations of which she had no notice and that minutes of that meeting misrepresented the content of the meeting
(ii) she received a letter from the second respondent dated 15 May 1996 in which the second respondent alleged that the appellant was not performing her duties properly
(iii) that without reasonable or proper basis or for any reasonable pedagogic purpose, the second respondent sought to have the appellant's teaching position restructured and that an inevitable effect of that would be to remove the appellant from her position
(iv) the first respondent withdrew funding for the position when the restructuring attempt was unsuccessful.
"(a) by reason of a characteristic that appertains generally to persons of the status or private life of the [subject] or (b) by reason of a characteristic that is generally imputed to persons of the status or the private life of the [subject] - the [alleged discriminator] treats the [subject] less favourably than he or she treats or would treat a person of a different status or with a different private life."
As his Honour said, the language of s.17 makes it apparent that sub-s.(4) should be read together with sub-s.(1). There are, as his Honour pointed out, a number of reasons for reading sub-section (4) with sub-section (1). First, the opening words of sub-s.(4), namely, "For the purpose of sub-section(1) ...", particularly when contrasted with the opening words of sub-s.(3), "For the purpose of this section ...", point to this conclusion. Secondly, if sub-s.(4) were not read with sub-s.(1), the comparison provided for in sub-s.(2) could not readily be applied in respect of conduct falling within sub-s.(4). If the two sub-sections are read together, however, there would be no difficulty in applying the comparison provisions of sub-s.(2) to the sub-s.(4) situation. Next, unlike the possible situation with sub-s.(5), sub-s.(4) does not meaningfully operate of its own volition. In other words, if sub-s.(4) were not read with sub-s.(1), conduct which fell within its ambit would not be proscribed by ss.21 to 23 because sub-s.(4) (unlike the situation with sub-s.(5)), would not by itself make such conduct discriminatory on the ground of "status" or "private life". Such conduct might be discriminatory conduct but absent its connection with sub-s(1), it would not amount to discrimination "on the ground of status or by reason of the private life of the person" within the meaning of, say, s.21(1) and would, therefore, not be proscribed. On the other hand, if sub-s.(4) were read together with sub-s.(1), any conduct that fell within sub-s.(4) would be regarded as constituting discrimination "for the purposes of sub-section (1)" and, therefore, would be regarded as discrimination on the above grounds and, thus, would fall to be proscribed by ss.21 to 23.
(a) that the subject has that attribute ...; (b) of a characteristic that a person with that attribute generally has; (c) of a characteristic that is generally imputed to a person with that attribute ...".
Direct discrimination occurs if the discriminator treats the subject with an attribute less favourably than he or she treats or would treat someone without that attribute or with a different attribute, albeit in the same or similar circumstances - s.8(1).
As I have said, the respondents claimed below and before us that the appellant's reserved social behaviour was no more than a personality trait and that this was not a "characteristic" within the meaning of s.17 of the 1984 Act. It was put below that, unlike physical characteristics such as skin, colour or objectively identifiable practices or conduct, such as dietary habits or mode of dress, personality traits differ from person to person and, with the same person from time to time. Thus, it was said, they do not fall within "characteristic" in the legislation. His Honour concluded, however, that personality trait of reserved behaviour was capable of constituting a characteristic within the meaning of s.17(4) of the 1984 Act and s.7(2) of the 1995 Act. Consequently, he concluded that ground (a) failed.
[1] Although for obvious reasons Professor Campbell is not a respondent to this appeal, where it is relevant to do so in these reasons, I shall continue to treat her as one of the parties.
[2] [1997] HCA 30; (1997) 191 C.L.R. 1 at 14-15 per Brennan C.J. and McHugh J.
[3] It is assumed for the purposes of this example that the requirement of religion X that its adherents pray as has been indicated is a relevant "characteristic" for the purposes of s.17(4)(a).
[4] The history of this sub-section does not assist in the interpretation of it. Nor are the relevant second reading speeches of any help on this issue. A provision similar to s.17(4) was first introduced into the then prevailing legislation, the Equal Opportunity Act 1977, by s.3 of the Equal Opportunity (Discrimination against Disabled Persons) Act 1982. That section inserted s.27A into the principal Act. As the name of the amending legislation suggests, the new provision was concerned with discrimination on the ground of impairment. Section 27A(1), like s.17(4), was concerned with characteristic based discrimination. Section 27A(2), which was similar to s.17(5), dealt with indirect discrimination. The wording of s.27A(1), however, was closer to that of s.7(2)(b) of the 1995 Act than it was to s.17(4) of the 1984 Act. In my view, however, nothing turns on this. So far as is relevant, s.27A(1) provided that a person discriminated against a subject on the ground of impairment "if on the ground of -
... (b) a characteristic that appertains generally to persons having or who have had that impairment; or (c) a characteristic that is generally imputed to persons having or who have had that impairment ... -
[the person treated the subject less favourably than a comparator]."
[5] Section 17(5) is in the following terms:
"For the purposes of sub-section (1) a person discriminates against another person on the ground of the status or by reason of the private life of the other person if:
(a) the first-mentioned person imposes on that other person a requirement or condition with which a substantially higher proportion of persons of a different status or with a different private life do or can comply;
(b) the other person does not or cannot comply with the requirement or condition; and
(c) the requirement or condition is not reasonable."
[7] [1995] VicRp 27; [1995] 1 V.R. 421 at 426.
[9] [1995] VICSC 90; [1995] 2 V.R. 418 at 424.
[15] (1998) 154 A.L.R. 693, at 670 per Hill, J.
[16] (1990) 26 F.C.R. 39 at 43.
Kapoor
Monash University and Anor [2001] VSCA 247