Fair Work Commission|2022-03-22

Kevin Pringle v Bhp Iron Ore [2022] FWC 554 (22 March 2022)

s.394 - Unfair dismissal

Application for an unfair dismissal remedy - circumstances not exceptional - application dismissed

[1] On 5 January 2022, Mr Kevin Pringle (Mr Pringle) filed an application (Application) pursuant to section 394 of Fair Work Act 2009 (Cth) (FW Act) with the Fair Work Commission (FWC) alleging he was unfairly dismissed from his employment with BHP Iron Ore on 13 December 2021 (BHP).

[2] An unfair dismissal application must be lodged with the FWC within 21 days after the dismissal takes effect. The FWC may only allow a further period for lodgement in exceptional circumstances.

[3] Mr Pringle has made an application for an extension of time to file his application. BHP oppose the application.

[4] Directions for the filing of materials were issued to the parties on 14 February 2022 (Directions). The Directions also required the parties to file a Statement of Agreement Facts.

[5] The materials filed by the parties did not disclose any factual dispute. In these circumstances, at the request of BHP and with the consent of Mr Pringle, I have determined whether to grant Mr Pringle an extension of time to file the Application solely on the materials filed by the parties without a hearing.

[6] Mr Pringle commenced employment with BHP on 14 January 1991. Since 28 September 2007 his employment has been governed by an Australian Workplace Agreement. His dismissal took effect on 13 December 2021.[1]

[7] At the time of dismissal Mr Pringle held the role of Shift Electrician at BHP's Port Hedland operations in the Pilbara region of Western Australia. To perform this role he was required to access BHP's work site at Finucane Island Port Hedland. [2]

[8] On 31 August 2021 the President of Mineral Australia sent an email to BHP employees, including Mr Pringle, foreshadowing that COVID-19 vaccination may become a condition of entry to BHP workplaces in Australia.[3]

[9] Between 31 August 2021 and 5 November 2021, Mr Pringle raised queries in relation to the COVID-19 vaccination with BHP and was provided with further information, including links to safety data sheets for the various COVID-19 vaccines then available, FAQ sheets relevant to his queries and contact details for medical professionals to discuss his concerns.[4]

[10] On 27 October 2021 Mr Brandon Craig, the Asset President for Western Australia Iron Ore, sent an email to BHP employees, including Mr Pringle, informing them that all BHP employees and contractors working in WA would have their site and workplace access revoked unless they: [5]

received and registered their first dose of an approved COVID-19 vaccine before 1 December 2021; or
had an approved medical exemption from 12.01am Wednesday 1 December 2021.

[11] On 28 October 2021, Mr Pringle wrote to the Western Australian Government regarding its intention to mandate COVID-19 vaccinations for resources workers, and on 30 November 2021 the Western Australian Government responded outlining the legal basis for its requirement.[6]

[12] On 2 November 2021, the Western Australian Government released the Resources Industry Worker (Restrictions on Access) Directions (No 1) (Resource Industry Directions (No 1)), which prevents a person who is a resources industry worker from entering a rural or remote resources industry site or remote operating centre if they have not been vaccinated against COVID-19 with a first dose of an approved COVID-19 vaccination by 1 December 2021, and a second dose by 1 January 2022. It also imposed obligations on BHP to collect evidence of vaccination by these dates.[7]

[13] Mr Pringle was a 'resource industry worker' for the purposes of the Resource Industry Directions (No 1), because BHP's work site at Finucane Island, Port Hedland, where he performed work, was a 'rural or remote resources industry site'.[8]

[14] On 9 November 2021, BHP emailed a letter to Mr Pringle, requesting evidence of a first dose of COVID-19 vaccination by 1 December 2021. The letter provided links to resources for further information and details on how applications for exemptions could be made.[9]

[15] On 12 November 2021, the Western Australian Government released the Resources Industry Worker (Restrictions on Access) Directions (No 2) (Resource Industry Directions (No 2)) which prevented a person who is a resources industry worker from entering a rural or remote resources industry site or remote operating centre if they have not been vaccinated against COVID-19 with a first dose of an approved COVID-19 vaccination by 1 December 2021, and a second dose by 1 January 2022. It also imposed obligations on BHP to collect evidence of vaccination by these dates.[10]

[16] Mr Pringle was a 'resource industry worker' for the purposes of the Resource Industry Directions (No 2), because BHP's work site at Finucane Island, Port Hedland, where he performed work, was a 'rural or remote resources industry site'.[11]

[17] On 19 November 2021, BHP emailed a letter to Mr Pringle, repeating its request for evidence of a first dose of COVID-19 vaccination by 1 December 2021. The letter inter alia stated that:[12]

"You are now being reasonably and lawfully directed to provide evidence of your vaccination status by 1 December 2021.

It is important you understand BHP's position that if you do not provide this information you will be treated as unvaccinated and you will not be permitted access to any BHP site after 1 December 2021. A failure to provide evidence of your vaccination status will be considered a failure to follow a lawful and reasonable direction and this may result in disciplinary action up to and including the termination of employment."

[18] During November 2021, Mr Pringle provided BHP with medical certificates that certified him as unfit for work from 2 November 2021 to 17 November 2021, and then 22 November 2021 to 30 November 2021. [13]

[19] On 25 November 2021, Mr Pringle applied for paid discretionary leave. This request was denied as Mr Pringle did not meet the eligibility requirements, but unpaid leave was approved for 22 November 2021 to 30 November 2021. [14]

[20] On 1 December 2021, Mr Pringle provided a medical certificate that advised that his wife was suffering from a medical condition and he was unable to attend work from 29 November 2021 to 12 December 2021. [15]

[21] Mr Pringle was stood down without pay commencing 1 December 2021.[16]

[22] On 8 December 2021, BHP emailed Mr Pringle inviting him to participate in a show cause meeting at 3:30pm the following day to show cause as to why his employment should not be terminated for: [17]

failure to comply with a lawful and reasonable direction; and
an inability to meet the inherent requirements of his role as a result of not providing evidence of having a COVID-19 vaccination or a valid exemption.

[23] On 8 December 2021, Mr Pringle sent a letter to BHP raising various legal challenges to the Direction and BHP's capacity to dismiss him. BHP provided a detailed response to his letter.[18]

[24] On 10 December 2021, Mr Pringle was invited to a meeting on 13 December 2021 at 9:30am. On 13 December 2021 Mr Gavin Warren (Supervisor E/Y Electrical), and Mr Joshua Cowan (Superintendent E/Y Execution) met with Mr Pringle at 9:30am to discuss his ongoing employment (Meeting).[19]

[25] Mr Pringle requested and was permitted to bring a support person with him to the Meeting.[20]

[26] At the end of the Meeting BHP dismissed Mr Pringle, effective immediately, and emailed him a letter confirming the termination of his employment in writing.[21]

[27] The Termination Letter described the reasons for termination as follows:[22]

"Failure to comply with the mandatory vaccination requirements in the Directions and failure to provide evidence of your vaccination status by the required date results in you not being able to access any rural or remote resources industry site or remote operating centre and perform the inherent requirements of your role. It is not possible for you to perform your role in a manner which does not require access to any site or BHP managed that is a rural or remote resources industry site or remote operating centre."

[28] Mr Pringle received payment in lieu of notice of termination.[23]

[29] On 4 January 2022, Mr Pringle filed claim U3 of 2022 with the Western Australian Industrial Relations Commission (WAIRC).[24]

[30] On 5 January 2022, a Senior Registry Services Officer (SRSO) from the WAIRC called Mr Pringle. The SRSO explained to Mr Pringle that the WAIRC's jurisdiction is limited to state based employers and employees and that large mining companies may fall within the jurisdiction of the FWC. Nevertheless, Mr Pringle decided to proceed with his application before the WAIRC.[25]

[31] On 5 January 2022, Mr Pringle filed the Application with the Fair Work Commission.[26]

[32] On 6 January 2022 the Chambers of Commissioner Cosentino of the WAIRC wrote to Mr Pringle as follows:[27]

"It's noted that named respondent to the application (BHP Iron Ore (Jimblebar) Pty Ltd EPA Western Australia) appears to be national system employer, such that the Commission is without jurisdiction to determine the claim."

[33] Mr Pringle did not discontinue his application in the WAIRC and on 28 January 2022, the WAIRC conducted a hearing attended by BHP. The WAIRC dismissed the claim for want of jurisdiction. Mr Pringle did not attend the hearing.[28]

[34] Subsection 394(2) of the FW Act provides that an application for an unfair dismissal remedy must be made 'within 21 days after the dismissal took effect', or within such further period as the FWC allows pursuant to subsection 394(3) of the FW Act.

[35] The 21 day period does not include the day on which the dismissal took effect."[29]

[36] If the final day of the 21 day period falls on a weekend or public holiday, the prescribed time will be extended until the next business day."[30]

[37] It is not in dispute and I find that the dismissal took effect on 13 December 2021. The date 21 days after the dismissal took effect was 3 January 2022. As this was an observed holiday in Western Australia for New Year's Day, the relevant filing deadline for the Application was midnight on 4 January 2022.

[38] The Application was filed one day out of time on 5 January 2022.

[39] The FW Act allows the FWC to extend the period within which an unfair dismissal application must be made only if it is satisfied that there are 'exceptional circumstances'. Exceptional circumstances are circumstances that are out of the ordinary course, unusual, special or uncommon, but the circumstances themselves do not need to be unique nor unprecedented, nor even very rare.[31] Exceptional circumstances may include a single exceptional matter, a combination of exceptional factors, or a combination of ordinary factors which, although individually of no particular significance, when taken together can be considered exceptional.[32]

[40] Section 394(3) of the FW Act requires that, in considering whether to grant an extension of time, the FWC must take into account the following:

the reason for the delay;
whether the person first became aware of the dismissal after it had taken effect;
any action taken by the person to dispute the dismissal;
prejudice to the employer (including prejudice caused by the delay);
the merits of the Application; and
fairness as between the person and other persons in a similar position.

[41] The requirement that these matters be taken into account means that each matter must be considered and given appropriate weight in assessing whether there are exceptional circumstances.[33]

[42] The test of exceptional circumstances establishes a high hurdle for an applicant to overcome for an extension to be granted.[34]

[43] Having taken into account the factors set out in sub-section 394(3) of the FW Act, ultimately, the power to grant an extension for the filing of an application which has been lodged out of time is a discretionary one.[35]

[44] The requirement that there be exceptional circumstances before the time for the lodgement of an application can be extended under section 394(3) of the FW Act contrasts with the broad discretion conferred on the FWC under section 185(3), to extend the 14 day period within which an enterprise agreement must be lodged, which is exercisable simply if in all the circumstances the Commission considers that it is 'fair' to do so.

[45] The onus is on Mr Pringle to provide a credible reason for the delay.

[46] While the delay to be considered is the period subsequent to the expiration of the 21 day period, the circumstances from the time of the dismissal may be relevant in determining whether the reason for the delay constitutes exceptional circumstances.[36]

[47] In Diotti v Lenswood Cold Stores Co-op Society t/a Lenswood Organic,[37] the Full Bench explained the correct approach by reference to the following example:

"For example if an applicant is in hospital for the first 20 days of the 21 day period this would be a relevant consideration if the application was filed 2 days out of time as occurred in this matter."

[48] The reason for the delay is not in itself required to be an exceptional circumstance. It is one of the factors that must be weighed in assessing whether, overall, there are exceptional circumstances.[38]

[49] The absence of any explanation for any part of the delay will usually weigh against an applicant in the assessment of whether there are exceptional circumstances, and a credible explanation for the entirety of the delay will usually weigh in the applicant's favour, however all of the circumstances must be considered.[39]

[50] The FW Act does not specify what reason for delay might tell in favour of granting an extension. However, decisions of the FWC have referred to an acceptable or reasonable explanation. Ignorance of the 21 day timeframe is not, of itself, an exceptional circumstance.[40]

[51] It appears that Mr Pringle was aware that a time limit applied to the lodgement of the Application:[41]

"It was with dismay that I realised I was about to miss the cut-off date for submission, so I completed the F2 form on 4th January 2022..."

[52] The form was received by the WAIRC at 1pm on 4 January 2022.

[53] Mr Pringle says he did not complete an application form until 4 January 2022 because:

A medical injury sustained by his wife to her ankle requiring her to use crutches resulted in him having caring responsibilities.
He suffered stress due to the loss of income when both he and his wife lost their employment because they both declined to be vaccinated.
His adult child, her husband and their children moved into his home in Perth because they were also unvaccinated.
As a consequence of his daughter's family moving into his home in Perth he and his wife relocated to a rural location in the south west of Western Australia which had poor mobile and internet reception.
He was busy renovating the rural property to make it suitable for he and his wife.

[54] He says that after receiving the call from the WAIRC on 5 January 2022 he went immediately to the nearest town to lodge his application with the FWC. The Application was received by the FWC at 4:23pm on 5 January 2021.

[55] The injury to his wife's ankle occurred on 23 November 2021.[42] Mr Pringle provided a medical certificate for the period 29 November 2021 to 12 December 2021. This period pre-dated his dismissal which occurred on 13 December 2021.[43] There is no medical evidence in relation to his wife's incapacity or his caring responsibilities after 12 December 2021. Nor is it clear how these caring responsibilities would prevent him from completing an application form for 21 days.

[56] Financial and emotional stress as a consequence of dismissal is something that unfortunately is experienced by most unfair dismissal applicants. For example, in Battigelli v Respiratory West Pty Ltd[44], the applicant cited mental health issues arising from dismissal related stress. Deputy President Beaumont noted that:[45]

"It is common for employees to suffer shock and trauma because of dismissal from employment."

[57] There is no evidence before me to suggest that Mr Pringle was so incapacitated by the stress of the loss of his and his wife's income that he was unable to make the Application within the required period.

[58] Having his daughter, her partner and his grand children move into his home and relocating with his wife to another property would no doubt have been disruptive however having to relocate following a loss of a job is not uncommon or unusual.

[59] As Commission Williams observed in Massey v Centrecare[46] in which the applicant submitted the delay was due to public holidays, packing her house and selling things to make money to afford her rent:[47]

"Regrettably disruption to people's accommodation and financial stress is not an uncommon consequence of unemployment and these are not exceptional circumstance. The occurrence of public holidays is also not an exceptional circumstance."

[60] To the extent Mr Pringle had difficulty accessing technology, this was due to his choice to travel to his country property with his wife close to his filing deadline. Having difficulty accessing the internet is not uncommon in rural areas however as Deputy President Asbury noted in Humphrey v Incitec Pivot Ltd:[48]

"... many persons who reside in rural areas are able to make applications to the Commission within the required time".

[61] I note that he was able to access the internet in a nearby town to be able to file the Application at short notice when he discovered it was filed in the wrong jurisdiction.

[62] I also note the comments of Commissioner Bissett in Murray v Ambulance Victoria[49] in which the applicant like Mr Pringle had waited until the final day to make an application. In finding against the applicant Commissioner Bissett commented that:[50]

"... while it is the period of the delay which is relevant, the lack of activity by Mr Murray prior to the expiration of the 21 days tells against an adequate explanation for the delay."

[63] Given the detailed correspondence Mr Pringle engaged in with both his employer and various other bodies prior to his dismissal and his demonstrated capacity to complete and lodge the WAIRC application and the FWC applications within short time frames it is clear that he posses the capability and capacity to make a claim in a timely manner.

[64] I consider the evidence before me provides a reasonable explanation for some but not all of the delay. The absence of an acceptable explanation for all of the delay weighs against a conclusion that there are exceptional circumstances.

Did Mr Pringle first become aware of the dismissal after it had taken effect?

[65] Mr Pringle was issued with the show cause letter on 8 December 2021 foreshadowing the possibility of his dismissal. Mr Pringle was aware of his dismissal as soon it took effect and therefore had the full period of 21 days to lodge the Application. This factor weighs against Mr Pringle being granted an extension.[51]

Did Mr Pringle take action to dispute the dismissal?

[66] Action taken by an applicant to contest the termination, other than by virtue of making the application will be relevant and may weight in favour of granting the extension of time.[52]

[67] Mr Pringle sent correspondence to his employer and various other bodies contesting the lawfulness of the vaccine mandate prior to his dismissal. However, there is not evidence of him taking action to dispute his dismissal after 13 December 2022 until he filed his claim in the WAIRC at 5:08am on Tuesday 4 January 2022.[53]

[68] This action taken to dispute the dismissal is not 'exceptional' in character such as to warrant an extension of time. In Robertson v Zeugma Electrical and Communications Services Pty Ltd[54] the applicant alike Mr Pringle also incorrectly initially lodged in a claim in the WAIRC. In dismissing the application, Deputy President McCarthy commented that:[55]

"...there is nothing exceptional about lodging in the WAIRC when the application should have been lodged in FWA [now the FWC] ... The FW Act does not provide for an application to be allowed if there has been mere inadvertence or accident Applicant."

[69] In McGuire v St John of God Hospital[56], Commissioner Williams denied an extension in relation to an applicant who commenced an incorrect (Unlawful Termination) claim with the Commission within time, and a correct claim was filed a week later (out of time).

[70] Mr Pringle did not take action to dispute the dismissal after his dismissal other than to file a claim in the WAIRC on the final day of the 21 day filing period. This factor weighs against Mr Pringle being granted an extension of time.

[71] Prejudice to the employer will go against the granting of an extension of time. The mere absence of prejudice to the employer is an insufficient basis to grant an extension of time.[57]

[72] The employer must produce evidence to demonstrate prejudice. It is then up to the employee to show that the facts do not amount to prejudice.

[73] A long delay gives rise "to a general presumption of prejudice".[58]

[74] I cannot identify any prejudice that would accrue to BHP if an extension of time were to be granted. However, if one were to consider the absence of prejudice as favouring of an extension, I would attribute it little weight in consideration of whether there are exceptional circumstances. The mere absence of prejudice to the employer is an insufficient basis to grant an extension of time.

[75] If a claim has merits, this will weight in favour of the grant of an extension of time.[59]

[76] In considering the merits of an application for an extension of time, the FWC is not normally in a position to make findings of fact on contested issues because to do so would require the parties in effect to present their evidentiary cases twice.[60]

[77] Mr Pringle says that his Application if it were to proceed has merit because there was no valid reason for his dismissal.

[78] The requirement for Mr Pringle to produce evidence of a first dose of COVID-19 vaccination to his employer, and the timing for that requirement, was set by the Western Australian government through the Direction. Mr Pringle was forewarned of this requirement and the consequences for his failure to comply with it. His employer engaged extensively with him in an effort to address his concerns with respect to this requirement. Mr Pringle failed to comply with the Direction. This failure meant that he was legally prohibited from attending his normal workplace from 1 December 2021 preventing him performing the inherent requirements of his role. The disciplinary process adopted by BHP was orthodox. BHP invited him to show cause why he should not be dismissed. He was permitted to have a support person attend the meeting held to discuss his proposed dismissal.

[79] Mr Pringle's circumstances are not dissimilar to many unfair dismissal applications heard by the FWC in recent months brought by applicants in similar circumstances to Mr Pringle. In relation to those applications the FWC to date has:

a. consistently upheld the dismissal of workers who have failed to comply with COVID-19 (and other public health orders (PHO) vaccination requirements; [61]
b. denied applications for extensions of time regarding this cohort;[62] and
c. found that the existence of an applicable PHO is a matter that indicates an application has low prospects when assessing exceptional circumstances.[63]

[80] On the material currently before me the Application has low likelihood of success. This weighs against the granting of an extension of time.

Fairness as between the person and other persons in a similar position

[81] The FWC may have consideration to fairness in matters of a similar kind that are currently before the FWC or have been decided in the past. This consideration is concerned with the importance of the application of consistent principles in cases of the same kind; however, cases of the same kind often turn on their own facts.[64]

[82] As Commissioner Bissett observed in Murray at [48]:

"In considering whether I should grant an extension of time, I need to have regard to whether it is fair to other unfair dismissal applicants whose applications are either currently before the Commission, or have been decided in the past. It would be unfair to other persons who have not been allowed a further period to make an unfair dismissal application in the absence of exceptional circumstances."

[83] The FWC has recently denied extension of time applications for claims commenced one day out of time.[65] The FWC has also previously denied extension of time applications in circumstances where an employee commenced an incorrect claim within time then filed the correct claim later.[66]

[84] Taking into account the criteria set out in section 394(3) of the FW Act, there is no exceptional circumstance that differentiates Mr Pringle's circumstances from the circumstances of these other individuals whose extension of time applications have recently been denied in a public health order context.[67]

[85] These decisions weight against the granting of an extension of time.

[86] Having regard to the matters I am required to take into account under section 394 of the FW Act, and all of the matters raised by Mr Pringle, I am not satisfied that there are exceptional circumstances in this case, either when the various circumstances are considered individually or together.

[87] As I am not satisfied that there are exceptional circumstances, there is no basis for me to allow an extension of time. I therefore decline to grant an extension of time under section 394(3) of the FW Act.

[88] Accordingly, Mr Pringle's Application for an unfair dismissal remedy must be dismissed. An Order[68] to this effect will be issued with this Decision.

[29] Singh v Trimatic Management Services Pty Ltd [2020] FWCFB 553, [10]. See also Acts Interpretation Act 1901 (Cth) s 36(1) as in force on 25 June 2009; Fair Work Act 2009 (Cth) s 40A.

[30] Ibid; Stedman v Transdev NSW Pty Ltd [2015] FWCFB 1877.

[31] Nulty v Blue Star Group Pty Ltd [2011] FWAFB 975, [13].

[33] Stogiannidis v Victorian Frozen Foods Distributors Pty Ltd [2018] FWCFB 901, [39].

[34] Diotti v Lenswood Cold Stores Co-op Society t/a Lenswood Organic [2016] FWCFB 349 at [16].

[35] Kyvelos v Champion Socks Pty Ltd (unreported, AIRCFB, Giudice J, Acton SOP, Gay C, 10 November 2000) Print T2421 at [8].

[36] Diotti v Lenswood Cold Stores Co-op Society t/a Lenswood Organic [2016] FWCFB 349 at [31].

[38] Stogiannidis v Victorian Frozen Foods Distributors Pty Ltd [2018] FWCFB 901, [39].

[40] Nulty v Blue Star Group Pty Ltd [2011] FWAFB 975; (2011) 203 IR 1 at [14].

[45] Ibid at [23] citing Howard v Medical and Aged Care Group T/A Humphries Road Medical Clinic [2018] FWC 3454 at [19].

[51] Meek v Baycorp Pty Ltd t/a Baycorp Pty Ltd [2016] FWC 1291 at [15].

[52] Brodie-Hanns v MTV Publishing Ltd (1995) 67 IR 298 at 300.

[58] Brisbane South Regional Health Authority v Taylor [1996] HCA 25; (1996) 186 CLR 541 at 556.

[59] Haining v Deputy President Drake (1998) 87 FCR 248, 250.

[60] Kyvelos v Champion Socks Pty Ltd (AIRCFB, Giudice J, Acton SOP, Gay C, 10 November 2000) Print T2421 at [14].

[61] See for example: Floors Aucamp v Association for Christian Senior Citizens Homes Inc [2021] FWC 6669; Edwards v Regal Cream Pty Ltd [2022] FWC 257; Shepheard v Calvary Health Care T/A Little Company Of Mary Health Care Limited [2022] FWC 92.

[62] See for example: O'Dea v Grampians Health [2022] FWC 362; Yates v Dahlsens Building Centres Pty Ltd [2022] FWC 329; Ainslie v Groot Eylandt Mining Company Proprietary Limited [2022] FWC 304; Fried v Travel Management Services Pty Ltd [2022] FWC 261; Massey v Centrecare [2022] FWC 250; McIntosh v Barwon Health [2022] FWC 227; Potapova v Alfred Health [2022] FWC 225; Murray v Ambulance Victoria [2022] FWC 215; Scanlan v Aged Care and Housing Group Inc [2022] FWC 174; Ferrato v Virtus Diagnostics [2021] FWC 6460; Petherick v Estia Investments Pty Ltd [2021] FWC 6274.

[63] See Murray v Ambulance Victoria (n 62) at [46]-[47]; McGuire at [26].

[64] Andrew Green v Bilco Group Pty Ltd [2018] FWC 6818 at [31].

[65] See for example Battigelli v Respiratory West Pty Ltd [2022] FWC 25 and Murray v Ambulance Victoria (n 62).

[67] See for example: O'Dea v Grampians Health (n 62); Yates v Dahlsens Building Centres Pty Ltd (n 62), Ainslie v Groot Eylandt Mining Company Proprietary Limited (n 62); Fried v Travel Management Services Pty Ltd ( n 62); Massey v Centrecare (n 62), McIntosh v Barwon Health (n 62); Potapova v Alfred Health (n 62); Murray v Ambulance Victoria (n 62); Scanlan v Aged Care and Housing Group Inc (n 62); Ferrato v Virtus Diagnostics (n 62); Petherick v Estia Investments Pty Ltd (n 62).

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Interpretation Act 1901

Kevin Pringle v Bhp Iron Ore [2022] FWC 554

At a glance

Court

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Judgment (145 paragraphs)

Kevin Pringle v Bhp Iron Ore [2022] FWC 554 (22 March 2022)

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Legislation Cited (2)

Cases Cited (4)