What happened

Mr Michael Kemp, age 75, had a long association with Hardwicks as a livestock buyer stretching back to the early 1990s (see [3]). On 3 May 2024 he was visited at home and told by a representative of Hardwicks that his services were no longer required (see [4], [23]). He filed a Form F2 unfair dismissal application on 7 July 2024 (see [5]), which was 44 clear days after the last date he could have filed under the 21-day rule prescribed by s 394(2)(a) of the Fair Work Act 2009 (the FW Act) (see [24]–[26]). Hardwicks filed a response on 20 July 2024 raising jurisdictional objections, notably lateness and that Mr Kemp was an independent contractor rather than an employee (see [6]).

The Commission programmed a determinative conference to decide whether to grant a further period for filing the application (see [7]–[8]). The matter proceeded as a determinative conference on 14 August 2024 (see [8], [11]). The Commissioner, after receiving evidence from Mr Kemp and his daughter and an uncontested witness statement from the respondent, considered whether "exceptional circumstances" under s 394(3) justified allowing an extension of time (see [10]–[12], [24]–[27]). The Commissioner determined that the effective date of dismissal was 3 May 2024 (see [23]), that the applicant's medical history did not provide a satisfactory explanation for the entire period of delay (see [31]–[36]), that Mr Kemp took no action to dispute his dismissal until close to filing (see [38]–[40]), and that the merits of the claim were weak because the arrangement bore trappings of an independent contractor relationship (see [42]–[44]). Taking all s 394(3) factors into account, the Commissioner concluded there were no exceptional circumstances, refused an extension and dismissed the application (see [46]–[50]).

Why the court decided this way

Statutory framework: section 394(2)(a) requires an unfair dismissal application to be filed within 21 days of the dismissal taking effect. Section 394(3) permits an extension only if the Commission is satisfied there are "exceptional circumstances" after considering specified matters (see [24]–[26]). The statutory list in s 394(3) requires consideration of the reason for delay, whether the applicant first became aware of the dismissal after it took effect, any action taken to dispute the dismissal, prejudice to the employer, the merits of the application, and fairness between persons in similar positions (see [26]).

Application of the law to facts: The Commissioner first fixed the effective date as 3 May 2024, making the filing deadline 24 May 2024; Mr Kemp filed on 7 July 2024 (44 days late) (see [23], [25]). The primary factual contest was whether Mr Kemp's health, serious hospital admissions February–April 2024 followed by convalescence, provided a satisfactory reason for the tardy filing. The Commissioner accepted that Mr Kemp was seriously ill earlier in the year and that he was in a period of convalescence after 1 May 2024 (see [14]–[18]). However, the medical material, including cardiologist notes from 20 May and 27 June 2024 that Mr Kemp "has done well" and is "back to his normal self", demonstrated clinical improvement by the relevant period and did not show incapacity preventing him from filing within the required time (see [20], [33]–[35]). The Commissioner emphasised the need for medical evidence where ill health is relied upon as the reason for delay (see [32]).

The Commissioner also considered Mr Kemp's conduct: he did not take steps to dispute his dismissal until shortly before filing (see [39]–[40]), which weighs heavily against extension. On merits, the remuneration arrangement, use of invoices from Camwin Pty Ltd associated with Mr Kemp, suggested an independent contractor relationship, casting doubt on whether Mr Kemp was a person protected by unfair dismissal provisions (see [42]–[44]). Taken together, the statutory factors did not lead to a conclusion of exceptional circumstances, and the extension was refused (see [46]–[49]).

Before and after state of the law

Before: The statutory regime and existing Fair Work Commission Full Bench authorities already established that extensions under s 394(3) are exceptional, that applicants must explain delays and ordinarily must lead medical evidence if relying on health, and that the merits of an application are a legitimate consideration when deciding extensions (see the authorities cited at [26], [27], [29], [32], [42]).

After: This decision applies those settled principles to the specific facts. It reinforces a strict approach: serious illness earlier in the 21-day period will not by itself establish exceptional circumstances if objective medical evidence shows recovery during the critical filing window and the applicant took no steps to contest the dismissal. It also reinforces that the presence of a real jurisdictional question on the merits (possible independent contractor status) is a material factor against granting extensions.

Practitioners should therefore expect limited scope to rely on past serious illness unless medical evidence specifically establishes incapacity during the filing window and there is prompt action to contest the dismissal.

Key passages with plain-English translation

Passage: "I find that 3 May 2024 was the effective date of dismissal for the purposes of s.394(2)(a) of the Act." ([23])
Plain English: The Commission decided Mr Kemp was dismissed on 3 May 2024; this date starts the 21-day clock.
Passage: "Mr Kemp does not have a satisfactory reason for the delay of 44 days between the last day for him to file his application and the date he eventually did." ([36])
Plain English: The court found the explanation (health/convalescence) did not convincingly account for why the application was late by 44 days.
Passage: "I consider Mr Kemp did nothing to dispute his dismissal, until close to the time he filed his application." ([39])
Plain English: He did not attempt to contest or raise the matter promptly; he only acted shortly before filing the late application.
Passage: "Some of the material in evidence shows the relationship between Mr Kemp and Hardwicks had trappings consistent with an independent contractor relationship..." ([42])
Plain English: Evidence about how he was paid (via an associated company) suggested he might not be an employee, which weakens the underlying claim.
Passage: "Having regard to all the matters identified in s.394(3) of the FW Act, I am not satisfied that there are exceptional circumstances." ([48])
Plain English: After looking at all the factors the law requires, the commissioner decided the rare condition for extending time was not present.
Passage: "I decline to grant an extension of time for the filing of the application. The application is dismissed." ([49]–[50])
Plain English: The Commission refused to allow a late filing and therefore threw out the unfair dismissal claim.

What fact patterns trigger this precedent

This decision is most directly engaged when:

An applicant files an unfair dismissal application significantly outside the 21-day window; and
The applicant relies on recent medical illness or hospitalization as the reason for delay; and
Medical records show improvement during the window such that incapacity during the full delay is not clearly established; and/or
The applicant took no or minimal steps to contest dismissal until shortly before filing; and/or
The substance of the claim raises real jurisdictional doubt (for example payments channelled through an associated company suggesting independent contractor status), so the merits factor weighs against extension.

In such fact patterns, expect the Commission to apply this reasoning and refuse extensions unless the applicant can produce contemporaneous medical evidence of incapacity during the relevant period or show other strong, objectively verifiable reasons for delay coupled with early steps to contest.

How later courts have treated it

This decision itself relies on Full Bench authorities and earlier Commission decisions (see [26]–[27], [29], [32], [35], [42], [45]) for the principles it applies. Because it is an individual Commission decision (not a Full Bench), it is persuasive at best. Future panels will likely cite this decision where the facts align, notably where a plaintiff relies on recuperation rather than ongoing incapacity. The decision reinforces existing precedent rather than creating new law: it follows the established "high hurdle" character of s 394(3) and the requirement for medical material and conduct showing active steps to dispute dismissal.

Practitioners should cite the decision for factual similarity, for example where an applicant has earlier serious hospitalisation but medical notes indicate improvement before the filing deadline, and where there was little action to dispute dismissal. The weight of the decision will depend on subsequent Full Bench or appellate treatment, which is not addressed in this decision.

Still-open questions

Degree of medical evidence required: The Commissioner applied established statements that medical evidence is required, but the precise threshold, for example, how contemporaneous or detailed the evidence must be to show inability to act, remains fact-specific and unresolved in generality. This decision suggests cardiologist notes indicating improvement will be insufficient where they show recovery before the deadline (see [33]–[35]).
Interaction of merits and discretion: The decision treated a real question as to employment status (independent contractor manifestations) as weighing against extension. The boundaries of how weak merits must be to influence the extension remain case-by-case. There is room for argument where merits are finely balanced whether that factor should be neutral rather than adverse.
Effect of self-representation and procedural assistance: The Commission conducted a determinative conference because the applicant was self-represented (see [8]). How much weight should be given to unfamiliarity with process (particularly for older applicants) as a mitigating factor will vary; this decision treated ignorance of process as not exceptional (see [35]). Whether more active administrative assistance by the Commission in early stages could alter outcomes has not been resolved.
Consistency across cases: The Commissioner noted a body of Commission decisions refusing extensions for delays of less than 44 days (see [45]). Given the high degree of factual variation, there remains tension about predictability. Parties will continue to seek distinctions based on the length and nature of delays, the quality of medical evidence, and conduct.

Practical takeaways: if relying on medical reasons for delay, secure contemporaneous medical evidence explicitly addressing capacity to pursue legal steps during the 21-day period; take early steps to dispute dismissal; and, where possible, avoid reliance on subjective or retrospective explanations about shock or emotional overwhelm alone.

Judgment (80 paragraphs)

[1]

Michael Kemp v Hardwicks Meat Works Pty Ltd atf Hardwicks Brothers Meatworks Trust [2024] FWC 2242 (22 August 2024)

[2]

Fair Work Act 2009

[3]

s.394 - Unfair dismissal

[4]

Hardwicks Meat Works Pty Ltd atf Hardwicks Brothers Meatworks Trust

[5]

Unfair dismissal application filed out of time - no satisfactory reason for delay - no exceptional circumstances - application dismissed

[6]

[1] Michael Kemp (Kemp) has made an application to the Fair Work Commission under s.394 of the Fair Work Act 2009 (Cth) (FW Act) for an order granting a remedy, alleging that he was unfairly dismissed by Hardwicks Meat Works Pty Ltd atf the Hardwicks Brothers Meatworks Trust (Hardwicks).

[7]

[2] Hardwicks is a livestock producer originating from West Central Victoria. It is part of the Kilcoy Global Foods Group.

[8]

[3] From about the early 1990's, Mr Kemp was engaged by Hardwicks as a livestock buyer - an engagement which extended for over 30 years. Mr Kemp is 75 years of age and has worked in the livestock industry for most of his life.

[9]

[4] On 3 May 2024 Mr Kemp was visited at home by Mr Phil Conway from Hardwicks and told that his services were no longer required.

[10]

[5] Mr Kemp filed a Form F2 Unfair Dismissal Application on 7 July 2024.

[11]

[6] Hardwicks filed a Form F3 Employer Response on 20 July 2024. Two jurisdictional objections were raised in relation to Mr Kemp's application. Firstly, Hardwicks submitted that Mr Kemp's application was not filed within 21 days of his dismissal taking effect. Secondly, Hardwicks submitted that Mr Kemp was not a person protected from unfair dismissal because he was not an employee of Hardwicks - that he was an independent contractor.

[12]

[7] I programmed the matter for a hearing or conference to determine whether to allow a further period for Mr Kemp's unfair dismissal application to be made, after having first issued directions for the filing of material in relation to that matter. I also made an Order that Mr Kemp produce documents, which he complied with.

[13]

[8] The matter was heard on 14 August 2024. At the start of the proceeding, I indicated my provisional view that it should be conducted as a determinative conference, taking into account that Mr Kemp was self-represented and so I could take a more active role in gathering evidence from the parties. There was no opposition by either party to this course and I conducted the proceeding as a determinative conference.

[14]

[9] Mr Kemp represented himself at the determinative conference and was assisted in doing so by his daughter, Ms Danielle Gaskett. I granted permission to Hardwicks pursuant to s.596 of the FW Act to be represented by a lawyer or a paid agent, and Mr Cardell-Ree represented Hardwicks in the determinative conference.

[15]

[10] During the conference, evidence was given by Mr Kemp and Ms Gaskett. A witness statement, which was uncontested, was also filed by Mr Peter McKnight for the Respondent.

[16]

[11] A range of material relevant to Mr Kemp's medical condition was produced by him and referred to by the Respondent. This material was organised in a Digital Hearing Book prepared by my chambers and marked during the determinative conference.

[17]

[12] There was no objection raised to the evidence of Mr McKnight nor was he required to present for cross-examination. The Respondent submitted that no adverse finding of credit should be made in respect of any person who gave evidence during the determinative conference, and that it accepted what was said during the conference by Mr Kemp and Ms Gaskett in relation to their evidence.

[18]

[13] It is convenient to separate Mr Kemp's recent medical history into two periods.

[19]

Mr Kemp's medical history between February and April 2024

[20]

[14] Evidence was presented in relation to a period of Mr Kemp's medical history beginning on about 3 February 2024, leading up to 1 May 2024. During this period, Mr Kemp experienced significant health challenges, and was admitted to hospital eight times, including:

[21]

On 28 February 2024 Mr Kemp was admitted to the intensive care unit at Sunshine Hospital with "dangerously low oxygen levels and an extremely fast heart rate". He was resuscitated in an emergency setting and placed on non-invasive ventilation in the intensive care unit, where he remained for several days.

[22]

On 12 March 2024 Mr Kemp was admitted to Shepparton Hospital after passing out at the Shepparton Sale Yards due to an abnormal heart rhythm.

[23]

On 22 March 2024 Mr Kemp was admitted to the Epworth Freemasons Hospital as a result of suffering from orthostatic hypertension.

[24]

On 22 April 2024 Mr Kemp was admitted to Melbourne Private Hospital with "heart failure". He was discharged on or about 30 April 2024. During this hospital stay he requested and was granted "day leave" to attend a cattle sale which he did.

[25]

During this period, Mr Kemp was required to attend dozens of medical appointments, including with respect to coronary care, with endocrinology, neurology, ophthalmology and diabetes specialists, and with his general practitioner.

[26]

[15] Ms Gaskett, who was generally at bedside during parts of each of Mr Kemp's hospital admissions and present at some of his medical appointments described Mr Kemp's health issues as "very serious" and that he was "extremely unwell". Mr Kemp described himself as "very ill through the time February, March and April". It seems clear from the evidence this was the case.

[27]

Mr Kemp's medical history between May and July 2024

[28]

[16] From about 1 May 2024 up until July 2024, Mr Kemp's recent medical history can be described by adopting a term he himself used in his evidence - a period of convalescence.

[29]

[17] During this period Mr Kemp was not admitted to hospital, although he attended a number of medical appointments (some of which may have required him to attend at a hospital for those appointments). His driver's license, previously suspended for medical reasons, was reinstated on 19 June 2024.

[30]

[18] It is clear from the evidence that during this period Mr Kemp's health was improving. Ms Gaskett said he was still in "significant recovery mode", but by 20 May 2024 described him as not "100%" but "much better" and during May and June, "getting back to baseline". There is no evidence that during the period between May and July 2024 Mr Kemp was suffering from any type of cognitive limitation.

[31]

[19] On 1 May 2024 Mr Kemp facilitated the provision to Hardwicks of two invoices from a Company called Camwin Pty Ltd in respect of work performed during April 2024 involving cattle purchases.

[32]

[20] On 20 May 2024 Mr Kemp visited Dr Adam Gay, Consultant Cardiologist, who said in a letter sent to Mr Kemp's GP, Dr Zebic that Mr Kemp "has done well since I last saw him", and that Mr Kemp had reported that "at this time he is back to his normal self". After a subsequent consultation on 27 June 2024, Dr Gay advised Dr Zebic that Mr Kemp "has remained well since I last saw him".

[33]

[21] Ms Gaskett explained that the more positive language being used to describe the state of Mr Kemp's health at around this time should be viewed in the context of how serious his health issues had been only a short time previously. She also described Mr Kemp as having a tendency to downplay his health issues, even when they were at their most serious - a trait she suggests is common to some of his generation.

[34]

[22] Mr Kemp's does appear to have stoic and resilient character. However, I do not consider his medical professionals would have used positive language to describe his improving state of health during this period of time simply because he urged them to. Their diagnosis is consistent with the general sense of the evidence that was presented about his health improvements during his convalescence period in medical statements and in his own evidence, and that of Ms Gaskett.

[35]

[23] While Mr Kemp's application for an unfair dismissal remedy suggests the date of the termination of Mr Kemp's employment was 2 June 2024, Mr Kemp confirmed in evidence that this was a mistake, and that he was advised of the end of his engagement with Hardwicks on 3 May 2024. I find that 3 May 2024 was the effective date of dismissal for the purposes of s.394(2)(a) of the Act.

[36]

[24] Section 394 of the FW Act requires that an application for an unfair dismissal remedy must be made within 21 days after the dismissal took effect. A further period of time may be allowed, but only if the Commission is satisfied that there are "exceptional circumstances".

[37]

[25] Mr Kemp's unfair dismissal application should have been filed within 21 days of 3 May 2024, or before midnight, 24 May 2024. It was filed on 7 July 2024. It was filed 44 clear days late.

[38]

[26] To determine whether "exceptional circumstances" exist warranting a further period for the application to be made (an "extension of time") the FW Act requires that I must give several factors consideration, evaluating and giving each of them due weight[1]. The factors are:

[39]

whether Mr Kemp first became aware of the dismissal after it had taken effect; and

[40]

any action taken by Mr Kemp to dispute the dismissal; and

[41]

prejudice to the employer (including prejudice caused by the delay); and

[42]

fairness as between Mr Kemp and other persons in a similar position.

[43]

[27] The test of exceptional circumstances in relation to extensions of time to lodge applications under s 394(3) establishes a "high hurdle" for an application for an extension[2].

[44]

[28] "The delay" is the period commencing immediately after the date upon which the application should have been filed, continuing until the date it was. In this matter, the delay is the 44 day period between the end of 24 May 2024 and 7 July 2024.

[45]

[29] This is the period of focus, although circumstances arising prior to that delay may often warrant consideration in assessing whether there is a credible reason for the delay, or any part of the delay, beyond the 21 day period. As a Full Bench of this Commission said:

[46]

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 out of time ...[3]

[47]

[30] Mr Kemp does not need to provide a reason for the entire period of the delay. However, 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[4].

[48]

[31] Mr Kemp said the reason for the delay was because of his health: that despite his "concerns" about the end of his engagement with Hardwicks, his greatest concern and focus was his health. In submissions, Ms Gaskett said that the unfair dismissal process is a "daunting process" and that it was not at the forefront of Mr Kemp's mind during the relevant period.

[49]

[32] It is well established that an applicant will need to lead medical evidence in support of an argument that a medical condition was the reason for the delay[5].

[50]

[33] Hardwicks submits that the material submitted in support of Mr Kemp's case that time should be extended in this matter does not suggest that his health issues prevented him from completing or impaired his capacity to complete an unfair dismissal application by the end of 24 May 2024 (and presumably, by implication, beyond that period). It submits that the medical evidence shows nothing "exceptional", of a medical nature, during the period after 3 May 2024 up until 24 May 2024 and there was nothing stopping Mr Kemp from filing the application within time. In its submissions, Hardwicks referred in particular to letters from Dr Gay, on 20 May 2024 stating Mr Kemp "has done well since I last saw him", and that Mr Kemp had reported that "at this time he is back to his normal self", and on 27 June 2024, that Mr Kemp "has remained well since I last saw him".

[51]

[34] Given the seriousness of Mr Kemp's medical issues during February, March and April 2024 it is not unreasonable to conclude that during his period of convalescence, his health issues impacted, to some extent, on his capacity to prioritise action he may have wished to take to contest the cessation of his engagement with Hardwicks. However, I am not convinced that those health issues, which had clearly diminished in severity during his period of convalescence, can be said to have been such that they prevented his ability to take the steps necessary to file his application if not before 24 May 2024, then sometime before 7 July 2024, or provide an adequate explanation for his failure to do so for this entire period of time.

[52]

[35] In reaching this conclusion, I have taken into account the relative unfamiliarity of the process to file an unfair dismissal application compared with other activities that might be more familiar to Mr Kemp, such as attending a cattle sale. I am not convinced that this is an adequate explanation, particularly when eventually, Mr Kemp did succeed in filing his application. It is well established that ignorance of the Commission's processes is not an exceptional circumstance[6].

[53]

[36] I find Mr Kemp does not have a satisfactory reason for the delay of 44 days between the last day for him to file his application and the date he eventually did. This factor weighs against a finding of exceptional circumstances and the granting of an extension of time.

[54]

Whether the person first become aware of the dismissal after it had taken effect.

[55]

[37] Mr Kemp accepted that he was told about the cessation of his engagement with Hardwicks on 3 May 2024. I consider this to be a neutral factor.

[56]

What action was taken by Mr Kemp to dispute the dismissal?

[57]

[38] In deciding whether to grant an extension of time in this matter I am required by the statute to take into account whether what if any action was taken to dispute the termination of employment.

[58]

[39] During the determinative conference, I asked Mr Kemp whether he did anything to dispute the cessation of his engagement with Hardwicks. He said he did not, until "close to the time" he filed his application, at which point he spoke to "Fair Work".

[59]

[40] I consider Mr Kemp did nothing to dispute his dismissal, until close to the end of the period of the delay. Given the length of the period between the effective date of dismissal and the filing of Mr Kemp's application, I consider the absence of any action at all to dispute the dismissal during this time weighs against a finding of exceptional circumstances and the granting of an extension of time.

[60]

What is the prejudice to the employer (including prejudice caused by the delay)?

[61]

[41] Hardwicks conceded that it has not suffered any particular loss and has not made hiring decisions on the basis of Mr Kemp not contesting the dismissal within time. I consider this to be a neutral factor.

[62]

[42] Some of the material in evidence shows the relationship between Mr Kemp and Hardwicks had trappings consistent with an independent contractor relationship, not an employment relationship. In particular, Mr Kemp appears to have caused invoices for payment to be sent to Hardwicks by an entity which he is clearly associated with called Cawmin Pty Ltd, in respect of work he performed.

[63]

[43] While it is not necessary or appropriate for me to attempt to resolve contested issues of fact going to the ultimate merits of this application, undoubtedly, the remuneration arrangement between Mr Kemp, Hardwicks and the corporate entity Camwin Pty Ltd is at the least, a matter of significant weight in favour of a finding of an independent contractor relationship[7]. This in turn suggests that Mr Kemp's application is afflicted by a serious question as to whether he is a person protected by unfair dismissal, within the meaning of the FW Act.

[64]

[44] Hardwicks submitted that the matter set out in s.394(3)(d) "does not weigh in favour of a finding that the FWC has a basis to exercise its discretion to extend the time for Mr Kemp to lodge the application". I accept this submission.

[65]

Fairness as between Mr Kemp and other persons in a similar position

[66]

[45] Hardwicks in its submissions set out a range of decisions of the Commission in which an extension of time was refused, where the length of the delay was between 1 day and 42 days (and less than 44 days). Undoubtedly, the Commission's refusal in these decisions to exercise its discretion to extend time relates to the particular circumstances of each case, including circumstances where different issues are being agitated, or involving persons in dissimilar positions to that of Mr Kemp. The consideration in s.394(3)(f) is more concerned with "the importance of consistent principles in cases of this kind", thus ensuring fairness between persons in similar positions[8]. I find this to be a neutral factor.

[67]

Is the Commission satisfied that there are exceptional circumstances, taking into account the matters above?

[68]

[46] After some 30 years of providing service, in some capacity, to Hardwicks, it is perhaps not unsurprising that Mr Kemp feels aggrieved at having been somewhat abruptly told his services were no longer required. It may have been possible for the Respondent to handle the matter with more regard for Mr Kemp's dignity and many years of service. Be that as it may, the question I must determine is whether, having regard to the factors set out in s394(3) of the FW Act, there are exceptional circumstances justifying a further period of time for the application to be made.

[69]

[47] I have not found that any of the relevant factors I am required to consider weigh in favour of an extension of time being granted to Mr Kemp. I have found Mr Kemp does not have a satisfactory explanation for the delay and took no action to dispute the dismissal (until very close to the end of the delay) and that these factors weigh against the granting of an extension of time. I also find that the merits of Mr Kemp's application do not weigh in favour of the granting of an extension of time.

[70]

[48] Having regard to all the matters identified in s.394(3) of the FW Act, I am not satisfied that there are exceptional circumstances.

[71]

[49] I decline to grant an extension of time for the filing of the application.

[72]

Mr Kemp representing himself, assisted by Ms Gaskett

[73]

[1] Periklis Stogiannidis v Victorian Frozen Foods Distributors Pty Ltd t/as Richmond Oysters [2018] FWCFB 901 (Stogiannidis)

[74]

[2] Abu Murad v Command51 Services Pty Limited [2024] FWCFB 307 [26].

[75]

[3] Laetisha Diotti v Lenswood Cold Stores Co-op Society t/a Lenswood Organic [2016] FWCFB 349 [31]

[76]

[5] Australian Postal Corporation v Lili (Karen) Zhang [2015] FWCFB 5285 [22]; see also Woolworths Limited v Lin, YuDuo (Lynda) [2018] FWCFB 1643 [38], [67].

[77]

[6] Cheyne Leanne Nulty v Blue Star Group Pty Ltd [2011] FWAFB 975 [13], [14].

[78]

[7] Hendrik Van Der Sandt v Shahram Mehin & Shannon Group Services Pty Limited [2024] 2188 [39].

[79]

[8] Perry v Rio Tinto Shipping Pty Ltd [2016] FWCFB 6963 [41].

[80]

Printed by authority of the Commonwealth Government Printer

Michael Kemp v Hardwicks Meat Works Pty Ltd atf Hardwicks Brothers Meatworks Trust [2024] FWC 2242

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