[2012] FWAFB 8021

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FAIR WORK AUSTRALIA

DECISION

Fair Work Act 2009
s.604—Appeal of decision

B. Curtis
v
Darwin City Council
(C2012/4669)

JUSTICE ROSS, PRESIDENT
DEPUTY PRESIDENT SMITH
COMMISSIONER GOOLEY

MELBOURNE, 17 SEPTEMBER 2012

Appeal against decision of Commissioner Simpson [2012] FWA 5224 - s.604 Fair Work Act - unfair dismissal proceeding dismissed - ‘frivolous, vexatious or without reasonable cause’ - permission to appeal refused - appeals not an avenue to redress deficiencies in the manner in which the case was run at first instance.

1. Background

[1] On 2 July 2012 Commissioner Simpson dismissed Bridget Curtis’ unfair dismissal application on the basis that it was ‘frivolous, vexatious or without reasonable prospects of success’, within the meaning of s.587 of the Fair Work Act 2009 (the Act). 1 The Commissioner’s decision was based on his finding that on 30 January 2012 the parties had reached a binding settlement agreement in respect of that application. Ms Curtis (the Appellant) has appealed the Commissioner’s decision. The relevant background facts may be shortly stated.

[2] In June 2011, the Appellant was diagnosed with epilepsy and was told that she could not drive a vehicle or operate certain machinery at work until her condition improved or she received a medical clearance. 2 The Appellant was dismissed from her employment as a horticulturalist with the Darwin City Council (the Respondent) at a meeting at the Council on 16 December 2011. The reason given for the termination of the Appellant’s employment was that she was unable to fulfil the inherent requirements of her job and no suitable alternative employment was available. Mr Brian Lewis, an industrial officer with United Voice (the Union) also attended the meeting. After the meeting with the Council, Mr Lewis went with the Appellant to the Union office, to meet Erina Early.

[3] Ms Early is a senior industrial officer with the Union. She has been employed by the Union for about 6 years and dealt with unfair dismissal claims on a regular basis. The Appellant has been a member of the Union for about 10 years.

[4] During the meeting at the Union, the Appellant was extremely distressed, distraught and crying. 3 Ms Early said that the Appellant told her that she wanted to lodge an unfair dismissal application and that she was seeking reinstatement.4 Ms Early advised the Appellant that the Union would lodge an unfair dismissal application on her behalf.5

[5] On 20 December 2011 the Union lodged an unfair dismissal application on the Appellant’s behalf. 6

[6] On 10 January 2012 the Union received a notice of listing from Fair Work Australia informing them that a conciliation conference in respect of the application would take place at 9.45am on 30 January 2012. 7 In her witness statement the Appellant said that she did not recall receiving a copy of the notice of listing.8 We return to that issue later.

[7] It is common ground that Ms Early and the Appellant had three telephone conversations on 30 January 2012.

[8] Ms Early first telephoned the Appellant some time between 8.30am and 9.00am. It was a short conversation. Ms Early told the Appellant that a conciliation conference was to take place that day. The Appellant told Ms Early that she was working and asked her to ring her back. Ms Early said that she would call back in about 15 minutes, and did so. 9 The content of the second conversation between Ms Early and the Appellant was disputed before the Commissioner.

[9] Immediately after her second telephone conversation with the Appellant, Ms Early contacted Mr Frank Crawley (the Council’s General manager, Corporate Services) by telephone and put proposed settlement terms to him on the Appellant’s behalf. Mr Crawley advised that the Council would accept the proposed settlement and requested that the Union email him and Mr Scott Roffey with the outline of the proposed settlement in writing. Ms Early then sent an email to Messrs Crawley and Roffey in the following terms:

[10] Mr Crawley replied by email stating: ‘The Council will agree to the request.’

[11] Ms Early then advised the Unfair Dismissals Team of FWA that the matter had settled and the conciliation conference was to be vacated.

[12] It is common ground that there was a subsequent, third, telephone conversation between Ms Early and the Appellant on 30 January 2012. We deal later with the content of that telephone conversation.

[13] A draft deed was supplied to Ms Early by email on Tuesday 31 January 2012 to which Ms Early replied, also on Tuesday 31 January 2012 “[T]he draft deed of settlement is fine”. 10 According to Ms Early she then attempted to contact the Appellant without success. As she was going to Sydney she asked Mr Lewis of the Union to contact the Appellant which he succeeded in doing on 9 February 2012 at which time the Appellant requested that the Union not proceed any further with the Deed as she was seeking legal advice.11

[14] It appears that the Respondent treated the matter as being settled despite the fact that the deed was never executed by the Appellant or the Union.

[15] On 16 February 2012 correspondence was received by the Tribunal from Mr Antony Downs of NT Law enclosing a Form F53 - Notice of Representative Commencing to Act - on behalf of the Appellant and requesting that the matter be set down for a further conciliation conference.

[16] On 30 March 2012 the Respondent filed a Form F4 - Objection to Application for Unfair Dismissal Remedy and further advised the Tribunal that the Respondent would not participate in any further conciliation of the matter until the objection to the application was heard and determined.

[17] The Respondent’s jurisdictional objection was heard by Commissioner Simpson on 18 June 2012.

[18] The central issue for determination in the proceedings before the Commissioner was whether there was an agreement to settle the unfair dismissal proceedings. That issue gave rise to two subsidiary questions. First, whether had the Appellant provided any instructions, or any competent instructions, to Ms Early to settle the proceedings on the basis ultimately agreed between Ms Early and the Respondent’s representative. This question turned on the substance of the conversations that took place between the Appellant and Ms Early on 30 January 2012. The second question was whether the settlement agreement was conditional upon the parties executing a deed in the terms agreed.

[19] The Commissioner upheld the Respondent’s objection and dismissed the Appellant’s application. The Commissioner’s conclusion is set out below:

2. The Appeal

[20] An appeal under s.604 of the Act is an appeal by way of rehearing and the Tribunal’s powers on appeal are only exercisable if there is error on the part of the primary decision maker. 12 There is no right to appeal, rather an appeal may only be made with the permission of the Tribunal. Section 604(2) deals with permission to appeal:

[21] However, different, more stringent, requirements are prescribed by s.400 of the Act in relation to appeals concerning applications alleging unfair dismissal. In respect of such appeals, s.400 of the Act provides:

[22] Section 400 manifests an intention that the threshold for a grant of permission to appeal is higher in respect of unfair dismissal appeals than the threshold pertaining to appeals generally (compare s 604(2) and s 400). In Coal & Allied Mining Services Pty Ltd v Lawler and others, Buchanan J (with whom Marshall and Gowdroy JJ agreed) characterised the test under s.400 as ‘a stringent one’. 13

[23] Before turning to the question of permission to appeal, we propose to deal with the Appellant’s submission that the Commissioner made a number of errors of law and significant errors of fact. In the course of the appeal hearing it was agreed that the Appellant’s submissions could be reduced to two lines of argument:

[24] The Appellant also submits that the Commissioner made four ‘significant errors of fact’:

[25] We doubt that matters (iii) and (iv) can be properly characterised as errors of fact. If the Commissioner erred in the manner suggested the error may amount to a failure to have regard to a relevant consideration. In other words it would be a House v King error, not an error of fact.

[26] It is convenient to deal first with the alleged errors of fact. In essence, the Appellant submits that no instructions were provided to Ms Early to settle the claim on the basis upon which it was purportedly settled. This submission is directed at the Commissioner’s finding that he preferred the evidence of Ms Early to that of the Appellant in relation to the two disputed telephone conversations between them on 30 January 2012.

[27] In relation to the extent of the ‘instructions’ provided by the Appellant to Ms Early, the Appellant contends that the Commissioner erred in preferring Ms Early’s evidence to that of the Appellant, in relation to the content of the telephone conversations between them on 30 January 2012.

[28] Ms Early’s evidence as to her recollection of the second telephone conversation is set out in her first witness statement:

[29] The Appellant’s evidence was that she told Ms Early words to the effect “I wanted my job back and they can pay for what they have done to me”. 14 Ms Early agreed under cross examination that the Appellant had said she wanted her job back15, however according to Ms Early later in the conversation it was clear that was not what the Appellant ultimately sought as part of a settlement.16

[30] The version of the relevant part of the same conversation in the Appellant’s statement is as follows:

[31] It is common ground that there was a subsequent, third, telephone conversation between Ms Early and the Appellant. The content of that conversation is also disputed. Ms Early said she contacted the Appellant to congratulate her on the successful outcome of discussions with the Respondent and informed her that the conciliation would not proceed as the parties had agreed to settle. Ms Early claims the Appellant then thanked her for her assistance. 17

[32] The version of this subsequent conversation provided by Ms Early is at odds with the version provided by the Appellant. The Appellant’s evidence as to this conversation is set out in her witness statement:

[33] In her second witness statement Ms Early rejects the Appellant’s recollection of the second conversation on 30 January and reiterates her earlier evidence: ‘I contacted Ms Curtis later on 30 January and congratulated her on the successful outcome as Darwin City Council were happy to agree to her terms of settlement of the matter. I further informed Ms Curtis that the conciliation would not proceed as the parties had agreed to settle the matter’. 18

[34] At paragraphs [65]-[67] of the decision subject to appeal, the Commissioner dealt with these evidentiary conflicts as follows:

[35] It is apparent from paragraph [66] of his decision that the Commissioner preferred Ms Early’s evidence to that of the Appellant, for two reasons:

[36] As to reason (i), the Commissioner made specific reference to inconsistencies in the Appellant’s evidence regarding her medical condition. The Commissioner deals with those inconsistencies earlier in his decision, at paragraphs [28]-[31]:

[37] The second reason given by the Commissioner for preferring Ms Early’s evidence to that of the Appellant, was the Commissioner’s rejection of the Appellant’s evidence regarding her knowledge of when the conciliation conference was to take place. The Appellant had denied having any notification at all of the conciliation conference being held on 30 January 2012. 33 The Commissioner deals with this issue at paragraphs [41]-[46] of his decision:

[38] On appeal no challenge was made to the Commissioner’s rejection of the Appellant’s evidence regarding her knowledge of when the conciliation conference was to take place.

[39] Two specific points are advanced by the Appellant in relation to the Commissioner’s findings on these matters:

[40] The difficulty with the first point is that it was never put in these terms on behalf of the Appellant in the proceedings before the Commissioner. At the conclusion of the evidence both parties made oral submissions. The Respondent went first and squarely put the proposition that the Commissioner should prefer the evidence of Ms Early to that of the Appellant:

[41] The Respondent’s representative then took the Commissioner to a number of inconsistencies in the Appellant’s evidence, including the Appellant’s evidence as to her medical condition and the emails sent by the Appellant to Ms Early on 7 February 2012.

[42] The response of the Appellant’s representative to the above submission was muted. In relation to issues of credit the Appellant’s submission is encapsulated in the following passages:

[43] Viewed in context, it is apparent that the Appellant’s counsel referred to the time it took Ms Early to review the Deed not so much as a credit issue but rather to support his proposition that the matter was settled to suit the convenience of Ms Early and Mr Crawley, with scant regard to the Appellant’s rights.

[44] On appeal the Appellant seeks to impugn Ms Early’s evidence by reference to what are said to be further inconsistencies between her oral evidence and her witness statements. For our part we are not persuaded that such inconsistencies arise, but the real point is that they were never put by the Appellant’s counsel to Ms Early in cross-examination. We are not persuaded that the Commissioner erred in the manner contended by the Appellant.

[45] One of the other ‘significant errors of fact’ alleged by the Appellant is also directed at the Commissioner’s finding that he preferred Ms Early’s evidence to that of the Appellant. The Appellant submits that the Commissioner erred in deciding that the emails sent to Ms Early on 7 February 2012 (set out at paragraph 38 above) supported Ms Early’s version of the third telephone conversion on 30 January 2012. We now turn to this aspect of the Appellant’s case.

[46] In rejecting the Appellant’s evidence the Commissioner referred to the inconsistencies in that evidence and observed at paragraph [66] of his decision that ‘I include in this inconsistency ... the evidence of ms Curtis regarding the impact of her medical condition’. This statement suggests that the Commissioner had regard to other inconsistencies, in addition to those relating to the Appellant’s medical condition. It is apparent from paragraphs [63]-[64] of his decision that the Commissioner was here referring to two emails sent by the Appellant to Ms Early on Tuesday 7 February 2012:

[47] The relevance of these emails to the Applicant’s credit was raised by the Respondent during the Appellant’s cross examination:

[48] The Appellant was also taken to this issue in re-examination:

[49] The Commissioner concluded that the emails of 7 February 2012 tended to support Ms Early’s version of her third conversation with the Appellant on 30 January 2012.

[50] On appeal, the Appellant submits that the Commissioner’s finding on this point was an error. We agree. A clear, plausible explanation was provided by the Appellant. In her evidence she says that she sent the email on the advice of the lawyers she had engaged after 30 January 2012. There was no real challenge to the Appellant’s explanation. But while we think the Commissioner’s approach to this issue was erroneous, we are not persuaded that the error was significant. It is apparent from paragraphs [66] of his decision that the 7 February emails did not feature prominently in the Commissioner’s decision to prefer Ms Early’s evidence.

[51] The other two ‘significant errors of fact’ referred to by the Appellant (see paragraph 25 (iii) and (iv) above) may be shortly disposed of.

[52] It is submitted that the Commissioner erred in failing to consider the parties’ rights under the deed in circumstances where it was a term of the deed that the parties obtain independent legal advice. There is no substance to this point. The deed was never executed and accordingly it did not confer any rights on the Appellant. The Commissioner did not err in the manner suggested by the Appellant.

[53] The final alleged significant error of fact is the proposition that the Commissioner erred in failing to consider the ‘medical evidence’ relating to the Appellant’s capacity to make an informed decision and provide proper instructions. The difficulty with this submission is that no ‘medical evidence’ is put to the Commissioner, a point conceded by the Appellant’s counsel in these proceedings. There can be no error in failing to have regard to evidence that was never put.

[54] There were no significant errors of fact in the decision subject to appeal. We now turn to the alleged legal errors.

[55] The first ‘legal error’ is the Appellant’s contention that the settlement ‘agreement’ entered into between Ms Early and the Council was of no effect because there was no consideration. The Commissioner considered, and rejected, a similar proposition in the proceedings at first instance at paragraph [727] of his decision:

[56] The Respondent submits that it is common knowledge that the right to resign is a valuable alternative to termination of employment for many reasons, including:

[57] For our part we accept that the right to resign is a common feature of unfair dismissal settlements and that it is of value to the dismissed employee. We agree with the Commissioner’s decision on this point, for the reasons he provides.

[58] It follows that to this point we have concluded that there was a properly authorised settlement agreement in respect of the unfair dismissal proceedings. The Agreement was reached in the telephone conversation between Ms Early and Mr Crawley and is evidenced in the subsequent email exchange. We have also concluded that there was no significant errors of fact in the decision. We now turn to the Appellant’s final legal point. The Appellant submits that if there was an agreement arising from the exchange between Ms Early and the Council’s representative then that agreement was dependant on the execution of the deed. As the deed was not executed it is submitted that there is no agreement.

[59] The ‘agreement’ is set out in Ms Early’s email to Messrs Crawley and Roffey, of 30 January 2012:

[60] The respondent replied, accepting the proposed terms. No deed of release was ever executed.

[61] At first instance the respondent submitted that the agreement fell into either class 2 or, in the alternative class 1 as identified in Masters v Cameron. 52 In that case the High Court held that where parties who have been in negotiation reach agreement upon terms of a contractual nature and also agree that the matter of their negotiation shall be deal with by a formal contract, the case may belong to any of three classes. The three classes are:

[62] In each of the first two cases there is a binding contract: in the first case a contract binding the parties at once to perform the agreed terms whether the contemplated formal document comes into existence or not, and to join (if they have so agreed) in settling and executing the formal document; and in the second case a contract binding the parties to join in bringing the formal contract into existence and then to carry it into execution.

[63] Cases of the third class are fundamentally different. They are cases in which the terms of agreement are not intended to have, and therefore do not have any, any binding effect of their own. The expressions ‘subject to contract’, ‘subject to the preparation of a formal contract’ and others of similar import prima facie create an overriding condition so that what has been agreed upon must be regarded as the intended basis for a future contract and not as constituting a contract of itself.

[64] At first instance the Commissioner was satisfied that there was a binding agreement between the parties. The Commissioner deals with this issue at paragraphs [68]-[70] and [74] of his decision, in these terms:

[65] In dismissing the Appellant’s argument, the Commissioner relied on the Full Bench decision in A Zoiti-Licastro v Australian Tax Office. 55 The relevant facts in that case are set out at paragraphs 4-6 of its decision:

[66] The Senior Deputy President at first instance in Zoiti-Licastro had found that the appellant had agreed to release the ATO from any liability arising from her employment by the ATO, save for personal injuries. He pointed out that the ATO’s solicitors had sent the appellant’s solicitors a facsimile letter on 4 March 2005 confirming the terms of settlement. The terms set out included the following: “5. Mutual releases by both parties in the usual terms.”

[67] The Senior Deputy President also referred to a settlement agreement sent to the appellant’s solicitors by the ATO’s solicitors a few days after the settlement discussions on 7 March 2005. That agreement contained mutual release provisions. In particular it contained a clause by which the appellant released the ATO from any liability arising out of the appellant’s employment with the ATO, other than claims by the appellant under the Safety, Rehabilitation and Compensation Act 1988 and/or the relevant superannuation legislation. The Senior Deputy President regarded it as significant that no objection had been raised to the facsimile letter of 4 March or the settlement agreement forwarded on 7 March until the indication on 31 March 2005 that the appellant did not want to go ahead with the settlement. Furthermore, counsel for the Appellant gave evidence that he had told his client that if she settled the proceedings she would be surrendering all of her rights, save any injury rights. This apparently took place before the conclusion of the discussions on 3 March 2005.

[68] The Full Bench dismissed the appeal in respect of this issue, stating:

[69] The second issue relied upon by the appellant in Zoiti-Licastro was that the agreement reached between Counsel was “subject to written terms”. It was submitted that the agreement could not be said to be completed until a document had been signed by both parties. The Full Bench also rejected this challenge to the Senior Deputy President’s decision also, in these terms:

[70] In the present matter the Appellant submitted that the decision in Zoiti-Licastro was distinguishable and that the circumstances in this matter fall into the third category in Masters v Cameron.

[71] Contrary to the Appellant’s submission the ratio of the decision in Zoiti-Licastro is relevant to the present matter. In that matter, a draft deed was prepared which went beyond the terms of the parties’ agreement. The Full Bench held that such a circumstance did not mean that the agreement reached was not binding. The same issue arises in this case and we are not persuaded that we should depart from the decision in Zoiti-Licastro.

[72] Nor are we persuaded that the Commissioner erred in his characterisation of the agreement between the parties. The settlement agreement was not expressed to be ‘subject to contract’ or an expression of similar import such as to create an overriding condition to the affect that what was agreed was the intended basis of a future contract, rather than constituting a contract of itself.

[73] The agreement in this case fell within either the first or second category in Masters v Cameron, in either case there was a binding contract.

3. Permission to Appeal

[74] As we have noted, the test for permission to appeal in respect of matters of this type is a stringent one. The Tribunal must not grant permission to appeal unless it considers that it is ‘in the public interest to do so’. The task of assessing whether the public interest test is met is a discretionary one involving a broad value judgment. As their Honours Mason CJ, Brennan, Dawson and Gaudron JJ said in O’Sullivan v Farrer:

[75] The public interest test in s.400(1) is not satisfied simply by the identification of error or a preference for a different result. In GlaxoSmithKline Australia Pty Ltd v Makin a Full Bench of the Tribunal identified some of the considerations that may attract the public interest:

[76] There was no significant errors of fact in the decision subject to appeal and the Appellant has failed to persuade us that the decision was tainted by legal error or that the discretion miscarried.

[77] In addition to the matters we have already dealt with, the Appellant advances a particular ground said to support the proposition that the appeal raises public interest considerations which warrant the grant of permission to appeal. This matter is dealt with at paragraphs 4.1 - 4.2 of the Appellant’s written outline:

[78] This submission is a variant of one of the other legal errors alleged by the Appellant (see paragraph 52 above). We accept that the draft deed went beyond the terms of settlement reached on 30 January 2012, in that it purported to settle all claims rather than being confined to the unfair dismissal proceedings. But as the Tribunal held in Zoiti-Licastro, the fact that a draft deed is prepared which goes beyond the terms of the agreement reached does not mean that the agreement is not binding. The same is true in the present case.

[79] It is also relevant to observe that the deed was never executed and accordingly it did not affect the Appellant’s rights. We are not persuaded that the argument advanced warrants the grant of permission to appeal.

[80] Permission to appeal is not a mere formality nor is it the function of the appeal process to provide an avenue for unsuccessful parties to seek to redress deficiencies in the manner in which their case was run in the proceedings at first instance. 58 The Tribunal and its predecessors have refused leave to appeal in circumstances where an appellant failed to lead evidence or to evidentially challenge the case put by the respondent in the proceedings at first instance.59 These observations are apposite in the present matter.

[81] The Appellant was represented by a legal practitioner in the proceedings below and was given a reasonable opportunity to present her case. The Appellant’s representative must bear responsibility for the fact that he failed to take the best advantage of the opportunity presented.

[82] The Commissioner, in our view, did everything that could be expected of him to ensure that the Appellant had a fair opportunity to present his case. He was not required to ensure that the Appellant took the best advantage of the opportunity presented. As Dean J observed in Sullivan v Department of Transport:

[83] Thisis simply a case where the member at first instance preferred the evidence of one witness to another for reasons which are clearly stated and entirely explicable. The role of an Appeal Bench in relation to findings of fact made by a member at first instance is necessarily limited. On appeal, the Tribunal would be very reluctant to reverse a finding of fact made by a member at first instance and would only do so if satisfied that any advantage enjoyed by the member below as a result of hearing the relevant evidence was not sufficient to justify the findings made. 61

[84] Appellate bodies are prepared to overturn findings of fact in certain circumstances, including where the tribunal at first instance acted on evidence which was inconsistent with facts incontrovertibly established by the evidence. 62 But if a finding made by a member at first instance depends to any substantial degree on the credibility of a witness, that finding will usually stand, unless it can be shown that the member at first instance:

[85] None of these factors are present in this case.

[86] We are not persuaded that it is in the public interest that permission to appeal should be allowed. Accordingly, we refuse the application for permission to appeal.

PRESIDENT

Appearances:

Mr B Taylor of counsel for the Appellant.

Ms E G Hartley of counsel for the Respondent.

Hearing details:

2012.

Melbourne:

5 September.

Videolink to Darwin and Perth.

 1   [2012] FWA 5224

 2   Exhibit 4 at paragraphs 17, 21 and 23; Transcript 18 June 2012 at paragraphs 501-502.

 3   Exhibit 4 Statement of Bridget Jane Curtis paragraphs 40-44; Exhibit 3 Statement of Ms Erina Early paragraph 43

 4   Transcript, at PN155

 5   Transcript, at PN 161.

 6   Exhibit 1 Statement of Mr Frank Crawley paragraph 11-14; Transcript PN 133; Respondent submissions appendix 1

 7   Exhibit 2 at paragraph 14.

 8   Exhibit 4 at paragraph 56.

 9   Exhibit 2 at paragraphs 21-23; Transcript 18 June 2012 at paragraphs 174-178.

 10  Draft Deed of settlement

 11   Exhibit 1 Statement of Mr Frank Crawley Paragraph 45

 12   This is so because on appeal FWA has power to receive further evidence, pursuant to s.607(2); see Coal and Allied v AIRC (2000) 203 CLR 194 at [17] per Gleeson CJ, Gaudron and Hayne JJ

 13   (2011) 192 FCR 78 at 90, paragraph [43].

 14   Exhibit 4 Statement of Bridget Jane Curtis Paragraph 63

 15   Transcript, at PN180-182

 16  Transcript, at PN190-197

 17   Exhibit 1 Statement of Mr Frank Crawley Paragraph 36-40

 18   Exhibit 3.

 19  Transcript, at PN866

 20  Exhibit 4 Statement of Ms Bridget Jane Curtis Paragraphs 19-24, 34, 39, 51, 66

 21  Transcript, at PN432

 22   Transcript, at PN441

 23  Transcript, at PN445-449

 24   Transcript, at PN507-510

 25   Exhibit 4 Statement of Bridget Jane Curtis BJC 1 page 4

 26   Transcript, at PN530

 27   Transcript, at PN551-557

 28   Exhibit 4 Statement of Bridget Jane Curtis BJC 1, MIMS CMI - Epilim page 3

 29   Transcript, at PN573-574

 30   Transcript, at PN696-709

 31  Transcript, at PN595

 32   Transcript, at PN722

 33   Transcript at paragraphs PN740-742.

 34   Exhibit 4 Statement of Bridget Jane Curtis Paragraph 56

 35   Exhibit 2 Statement of Ms Erina Early dated 23 May Paragraphts16-22

 36   Exhibit 3 Statement of Ms Erina Early Paragraph 56

 37   Transcript PN 603

 38   Transcript PN 616

 39   Exhibit 4 Statement of Bridget Jane Curtis Paragraph 62

 40   Transcript PN 633

 41   Transcript PN 634-637

 42   Transcript PN 560

 43   Transcript PN 173

 44   Exhibit 4 Statement of Bridget Jane Curtis Paragraph 60

 45   Transcript PN 620-623

 46   Transcript PN 169

 47   Transcript 18 June 2012 at paragraphs 828-830.

 48   Ibid at paragraphs 861 and 873.

 49  Exhibit 4 Statement of Ms Bridget Jane Curtis BJC 4

 50   Transcript, at PN638-654.

 51   Transcript, at PN745-748; PN781-783

 52   [1954] 91 CLR 353 at 360-361.

 53   Exhibit 1 Statement of Mr Frank Crawley Appendix 3

 54   Masters v Cameron

 55   PR967544

 56   (1989) 168 CLR 210 at 216; applied in Hogan v Hinch 92011) 85 ALJR 398 at [69] per Gummow, Hayne, Heydon, Crennon, Kiefel and Bell JJ; Coal & Allied Mining Services Pty Ltd v Lawler and others [2011] FCAFC 54 at [44] - [46].

 57   (2010) 197 IR 266 at [27].

 58   KA Murphy v SF Finance Pty, Print P1395, 29 May 1997.

 59   Monash Medical Centre Appeal, Print K7312; Brighton City Council v MOA Print J7019 and Motels Awrd Appeal (1977) 187 CAR 446.

 60   (1978) 20 ALR 323 at 343; Cf: Gaudron J, in Re: Association of Architects of Australia; Ex parte Municipal Officers Association of Australia (1989) 63 ALJR 298 at 305.

 61   Abalos v Australian Postal Commission (1990) 171 CLR 167 at 178 per McHugh J and Devries v Australian Natinal Railways Commission per Brennan, Gaudron and McHugh JJ.

 62   State Rail Authority v Earthline Constructions Pty Ltd (In Liq) (1994) 73 ALJR 306

 63   (See Devries v Australian National Railways Commission (1993) 177 CLR 472 at 479; Elitegold Pty Limited v CM Holdings Pty Ltd and Anor [1995] ATPR 40,753 at 47,759.

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