Dec 560/00 M Print S6238

AUSTRALIAN INDUSTRIAL RELATIONS COMMISSION

Workplace Relations Act 1996
s.45 appeal against decision and order Prints S3557 and S3558
issued by Senior Deputy President Williams on 25 February 2000

Tenix Defence Systems Pty Ltd
(C No. 31465 of 2000)

s.170CE application re relief in regard to termination of employment

K Fearnley

and

Tenix Defence Systems Pty Ltd
(U No. 30520 of 1999)

VICE PRESIDENT ROSS

 

SENIOR DEPUTY PRESIDENT POLITES

 

COMMISSIONER SMITH

MELBOURNE, 22 MAY 2000

Termination of employment - appeal - unfair dismissal - misconduct - fighting in workplace - self defence - approach of industrial tribunals when fighting has been established - role of appellate body in reviewing findings of fact at first instance.

DECISION

Background

[1] This decision deals with an appeal by Tenix Defence Systems Pty Ltd (Tenix) against the decision and order of Senior Deputy President Williams in Prints S3557 and S3558 made at Melbourne on 25 February 2000. Mr Keith Fearnley was the Applicant in the proceedings below and is the respondent in the matter before us. In the decision subject to appeal his Honour concluded that the termination of Mr Fearnley's employment was "harsh, unjust and unreasonable". His Honour then considered the question of remedy and decided that an order for reinstatement with maintenance of continuity of employment was appropriate. The order giving effect to his Honour's decision is in the following terms:

[2] Before we turn to examine the decision subject to appeal and the grounds advanced in support of the appeal we propose to briefly set out some of the background to the termination of Mr Fearnley's employment.

[3] The Applicant was employed as a marine operator by Tenix and its predecessor, Australian Marine Engineering Corporation Ltd, from 14 August 1989 to 10 February 19992 when his employment was terminated by the respondent. The termination of the Applicant's employment was a result of an incident on 10 February 1999 between the Applicant and a Mr Bardis. Mr Bardis was also a Tenix employee.

[4] A few days before the incident occurred the Applicant was told by Mr Bardis that he (Bardis) did not respect his team leader - a Brett Bizon - and intended to "fix him up" by rubbing off chalk marks which Mr Bizon had used to mark faulty workmanship. The chalk marks are used to identify faulty welds for reworking. Shortly after this conversation the Applicant told Mr Bizon of Mr Bardis' intentions. On 9 February 1999 the Applicant became aware that Mr Bardis had been spoken to about the matter. He became concerned that Mr Bardis would then be aware that he had passed the information to Mr Bizon. He anticipated that this could cause a problem between himself and Mr Bardis.

[5] On 10 February 1999 the Applicant was walking past the area in which Mr Bardis was working. Mr Bardis shouted loudly to the Applicant. The latter anticipated that Mr Bardis wanted to discuss the matter referred to earlier. After a moment's hesitation the Applicant decided to sort the problem out at that time rather than wait for Mr Bardis to raise the matter later in the lunch room before other employees. He walked towards Mr Bardis who threw his welding helmet on the ground and approached the Applicant.

[6] A brief exchange followed during which Mr Bardis did some finger pointing and swearing at the Applicant. When the Applicant was within an arms length of Mr Bardis he (Bardis) put his finger on the Applicant's throat. The Applicant pushed Mr Bardis' finger away and Mr Bardis then grabbed him by the throat in a way which severely inhibited the Applicant's breathing. Mr Bardis was choking the Applicant. A fight ensued during which the Applicant struck Mr Bardis on several occasions. As a result of the Applicant's blows Mr Bardis received a cut below his left eye that required medical attention.

[7] Tenix conducted an investigation into the incident and decided to terminate the employment of both men. The Applicant's employment was summarily terminated on 10 February 1999.

Decision at First Instance

[8] Mr Fearnley's s.170CE application for relief arising from the termination of his employment was heard on 16, 17 and 22 December 1999. On 25 February 2000 Senior Deputy President Williams issued a decision in which he found that the termination of Mr Fearnley's employment was "harsh, unjust and unreasonable" and decided to order reinstatement.

[9] In the proceedings at first instance Tenix submitted that it had a valid reason for dismissing the Applicant based on his conduct. Tenix dismissed Mr Fearnley because he had been involved in a fight with Mr Bardis in which he and Mr Bardis exchanged punches and Mr Bardis received a severe facial cut above his left eye. In support of this contention Tenix submitted that it had a clear policy that intimidating or assaulting employees was serious misconduct and could lead to summary dismissal.

[10] Tenix also submitted that the Applicant was notified of the reason for his dismissal (s.170CG(3)(b)) and had been given an opportunity to respond to that reason (s.170CG(3)(c)).

[11] In the event that the Commission determined that the termination of the Applicant's employment was "harsh, unjust or unreasonable" Tenix submitted that reinstatement should not be ordered because it would be inappropriate to do so. In this regard Tenix relied on the evidence of Mr Sullivan.3

[12] In reply Mr Addison, on behalf of the Applicant, submitted that there was no valid reason for the termination as Mr Fearnley had simply acted in self defence, as he was entitled to do. It was also argued that the investigation of the incident by Tenix was flawed and the Applicant was not provided with an opportunity to respond to the reason for his termination as the respondent never gave any consideration to the Applicant's contention that he was acting in self defence. It was argued that reinstatement was the appropriate remedy.

[13] His Honour's findings in relation to the incident between the Applicant and Mr Bardis are set out at paragraphs 15 - 18 of his decision, in the following terms:

[14] His Honour then considered the investigation by Tenix into the incident and found that "the manner in which the termination was effected was procedurally flawed."5 The Senior Deputy President then concluded in the following terms:

[15] His Honour then turned to consider the question of remedy and decided that an order for reinstatement with continuity of employment was appropriate.

Submissions on Appeal

[16] The Appellant challenged his Honour's findings and conclusions in respect of each of the matters referred to in s.170CG(3)(a) to (e). In particular it was submitted that his Honour erred in:

[17] It was also submitted that reinstatement should not have been ordered because it was inappropriate to do so.

[18] The essence of the Respondent's submission in reply was that his Honour's findings and conclusion were reasonably open and that the Appellant had failed to establish an arguable case in support of its contention that his Honour made a number of errors. On this basis it was argued that leave to appeal should be refused.

Consideration of Submissions

[19] The appellate jurisdiction conferred on us by s.45 in relation to an appeal concerning an order arising from the arbitration of an application under s.170CE is conditioned by s.170JF(1) which limits the grounds of an appeal. The only ground is that the member of the Commission who conducted the arbitration was in error in deciding to make an order. That can be an error of fact or an error of law.7 As the order subject to appeal is a discretionary one, the appeal is to be determined in accordance with the principles stated in House v The King.8 In House v The King, Dixon, Evatt and McTiernan JJ stated these principles as follows:

[20] In the light of the principles applicable to an appeal from a discretionary order, we now turn to consider whether an error within these principles was made by the Senior Deputy President in the exercise of his discretion.

[21] The focal point of the appeal was his Honour's conclusion that there was no valid reason for the termination of Mr Fearnley's employment. The Appellant advanced three submissions directed at this part of the decision subject to appeal. First, it was argued that his Honour had failed to apply the principles in Australia Meat Holdings Pty Ltd v McLauchlan10 to the matter before him. Second, the Appellant challenged the findings of fact upon which his Honour based his decision. Third, it was argued that his Honour had failed to give sufficient weight to the Appellant's policy on fighting.

[22] Before dealing with each of these submissions we wish to make some brief observations on the approach taken by industrial tribunals when fighting or an assault has been established. In AWU-FIME Amalgamated Union v Queensland Alumina Limited Moore J summarised the relevant decisions in the following passage:

[23] Not dissimilar views, albeit in a different statutory context, have been expressed by a Full Bench of the Industrial Commission of South Australia in Torbet v Commissioner for Public Employment as follows:

[24] The above passages were cited with approval by a Full Bench of the Commission in Mobil Oil v Giuffrida.13 We also note the following observation by the Federal Court - in another fighting case - Qantas Airways Limited v Cornwall:

[25] We think these authorities support the view that in determining whether there is a valid a reason for a termination of employment arising from a fight in the workplace the Commission should have regard to all of the circumstances in which the fight occurred including, but not limited to:

- whether the terminated employee was provoked and whether he or she was acting in self defence;

- the employer's need to establish and retain discipline amongst its employees; and

- the service and work record of the employee concerned.

[26] We now turn to consider the particular submissions advanced by the Appellant.

McLauchlan's Case

[27] As we have noted the Appellant submitted that his Honour failed to apply the principles in Australia Meat Holdings Pty Ltd v McLauchlan15 to the facts before him. McLauchlan's case is authority for the proposition that in determining an application under s.170CE(1)(a) the Commission is bound to consider whether the termination was "harsh, unjust or unreasonable" based on the evidence in the proceedings before it, provided that evidence concerns circumstances in existence when the decision to terminate the employment was made. Facts which existed at the time of the dismissal but which only came to light after the dismissal might either:

- justify the dismissal when otherwise it would be harsh, unjust or unreasonable; or

- render the dismissal harsh, unjust or unreasonable.

[28] In Mr Fearnley's case there were facts in existence which were not known to the employer in the course of its investigation. This new material was in evidence in the proceedings below but, the Appellant submits, his Honour failed to take this evidence into account or in the alternative he did not give it the weight it deserved.

[29] When seen in this light it seems to us that the submission in relation to McLauchlan's case is really just part of the Appellant's primary contention that a number of his Honour's findings were not reasonably open on the evidence before him and we now turn to deal with that contention.

Challenge to Findings

[30] The principal submission advanced in support of the appeal was that on any reasonable view his Honour was wrong in making the following findings:

- the Applicant was not a willing participant in the fight;

- the Applicant's conduct did not contribute to "what might be initially described as a confrontation turning into a fight"; and

- the Applicant was not "going on with it".

[31] These findings appear at paragraph 16 of the decision subject to appeal and the relevant passage is set out at paragraph 13 of this decision.

[32] In the proceedings at first instance the evidence in respect of what happened immediately prior to and leading up to the actual physical confrontation, and the fight itself consisted of the witness statements, and in some cases oral evidence, of the following persons:

[33] Messrs Bardis, Mallia and Lemon were not available for cross-examination and their evidence was not relied on by either party. In essence the only evidence of any real probative value relevant to his Honour's findings about the confrontation between the Applicant and Mr Bardis consisted of the statements and oral evidence of the Applicant and Messrs Morgan and Formosa.

[34] Before turning to the evidence in the proceedings at first instance we note that the role of an Appeal Bench in relation to findings of fact made by a member at first instance was recently considered by a Full Bench in Rode v Burwood Mitsubishi in the following terms:

[35] We propose to adopt the above analysis and apply it to the matter before us.

[36] In this case the Appellant contended that his Honour made no effort to resolve the inconsistencies in the evidence. But it is clear that his Honour's findings of fact were inconsistent with parts of the evidence of Messrs Morgan and Formosa. In such circumstances his Honour must be taken to have rejected that evidence and accepted the Applicant's evidence. As the High Court said in Abalos:

[37] We now turn to deal with the Appellant's challenge to the findings set out in the decision subject to appeal.

[38] The first two findings subject to challenge relate to what happened immediately prior to and leading up to the actual physical confrontation. The only probative evidence relevant to these findings is that of Mr Fearnley. Messrs Formosa and Morgan did not witness the events before the fight developed. The Appellant's submission in respect of Mr Fearnley's evidence is set out at paragraphs 27-31 of Exhibit A1. In particular at paragraph 27 the Appellant says:

[39] The Appellant also contended that the Applicant was uncertain and evasive throughout his oral evidence.

[40] In our view the first two findings subject to challenge were reasonably open on the evidence. The points advanced by the Appellant must be seen in the context of the Applicant's evidence as a whole. True it is that the Applicant admitted that he had opportunities to ignore Mr Bardis and retreat. In particular the Applicant conceded that he could have retreated when Mr Bardis first shouted at him and when he threw his welding helmet on the ground in an aggressive way. But at this stage the Applicant did not appreciate the seriousness of the impending confrontation. In his statement he says:

[41] This statement was confirmed in the Applicant's oral evidence when he said that at this stage he didn't know whether Mr Bardis was serious or not.26 The Applicant also admitted that he could have retreated when Mr Bardis started waggling his finger at him - at that stage the Applicant did appreciate that Mr Bardis was serious. But by the time the Applicant became aware of the seriousness of the confrontation it is also apparent that events were moving very quickly. As the Applicant put it: "It's not how you read it on the paper and what happened, actually. It happened within seconds ... I feel as though I never had a chance to retreat."27 We return to the duration of the incident shortly.

[42] We also note that during the course of his cross-examination the Applicant rejected the proposition that he responded in an aggressive way to Mr Bardis' aggression.28 In relation to the contention that the Applicant was uncertain and evasive throughout his oral evidence we do not think this is supported by a fair reading of the Applicant's evidence as a whole. We acknowledge that the Applicant was occasionally uncertain as to some of the details of the incident but as he says: "This is 12 months ago. It happened within a second or two."29

[43] The Applicant wasn't the only witness who had difficulty recalling all of the details of the incident given the passage of time. Mr Morgan had similar problems;30 as did Mr Formosa.31

[44] In relation to the third finding subject to challenge there is a clear conflict between the Applicant's evidence on the one hand and that of Messrs Morgan and Formosa on the other. Both Mr Morgan and Mr Formosa gave evidence that the Applicant continued to assault Mr Bardis when Mr Bardis' grip on the Applicant's neck had been released and Mr Bardis was hunched back against a wall "cowering" from the Applicant.32 The Applicant's evidence on this point appears in the following exchange:

[45] His Honour found that insofar as the Applicant punched Mr Bardis, he was not "going on with it" but rather was "reacting to a real threat to his physical well being".

[46] It is implicit in his Honour's finding that he preferred the Applicant's evidence on this point to that of Messrs Morgan and Formosa. While the decision subject to appeal does not detail his Honour's reasons for preferring the Applicant's evidence a number of factors support the view he took.

[47] First, there was evidence of some antipathy between the Applicant and Mr Morgan. Mr Morgan had been a member of the Applicant's union, the AMWU, but resigned and joined the AWU because as he put it "I didn't like the corruption that was going on in the yard".34 In his evidence the Applicant said that he "had a lot of problems" with Mr Morgan stemming from an incident in which the Applicant, acting on the instructions of his union, had gone through an AWU picket line.35 When asked whether he thought Mr Morgan had fabricated his account of the incident in order to get back at him for breaking a picket line the Applicant said: "Yes, I think he spiced it up. Yes."36 Mr Morgan denied that he had given his account of events because he had it in for the Applicant.37

[48] Second, Mr Formosa's view of the incident was limited. As he put it in his oral evidence:

[49] This is important because it could explain a conflict in the evidence of the Applicant and Mr Formosa. The Applicant maintained that after Mr Bardis let go of his neck he still had a hold of his arm and was punching him.39 In his evidence Mr Formosa maintained that at one stage Mr Bardis released his grip on the Applicant's neck and they separated.40 In their submissions in the proceedings at first instance Tenix relied on this evidence and that of Mr Morgan to support its contention that the Applicant continued to assault Mr Bardis after any relevant threat had disappeared.41 But Mr Formosa's account of the fight may simply reflect the position from which he viewed it and Mr Morgan's evidence on this point is far from unequivocal.

[50] Mr Morgan was not sure whether Mr Bardis had a hold of the Applicant throughout the fight as is apparent from the following extract from Mr Morgan's cross-examination:

[51] It is also relevant to note that the day after the fight the Applicant's doctor examined him and observed "tenderness and redness" on his upper arm. These injuries are consistent with the Applicant's evidence that Mr Bardis had a hold of his arm during the fight.43

[52] Two other points clearly emerge from the evidence and in our view they support his Honour's finding. First at an early stage in the confrontation Mr Bardis had his hands on Mr Fearnley's neck. Mr Fearnley's evidence on this point is set out in the following passage from his oral evidence:

[53] Mr Fearnley was not cross examined on this aspect of his evidence. Indeed during his cross-examination Mr Fearnley said "I was scared out of my wits and I wanted to get away, and I felt as though I was fighting for my life."45 The seriousness of Mr Bardis' assault is confirmed by the fact that some two hours after the incident Mr Formosa observed that the Applicant was distressed and was still having difficulty breathing. Mr Formosa also observed welts on the Applicant's neck.46 The day after the fight the Applicant consulted his doctor who noted that his examination of the Applicant revealed "tenderness and redness on both sides of the neck as well as on the upper arm".47 It should also be born in mind that Mr Bardis is a more physically imposing figure than the Applicant. Mr Formosa described Mr Bardis as being 5'10" tall, stocky build weighing around 14-15 stone. The Applicant is a much smaller man - about 5'7" and 11 stone.48

[54] Second, the actual physical confrontation was over in a matter of seconds. Mr Formosa was some 25 metres from Messrs Bardis and Fearnley when he became aware of the fight. He started moving quickly towards them. At that time Mr Bardis had his hands on the Applicant's neck. Mr Formosa then saw the Applicant throw two or three high punches but did not see the punches connect. At this stage Mr Formosa was jogging towards the other two men and was only some 10 metres away. On his own evidence he was "travelling very fast" and it took him just five or six seconds to reach them and break up the fight.49

[55] The evidence of both Mr Morgan50 and the Applicant confirm that the incident was over very quickly. Mr Fearnley said "It felt like just a few seconds. It was like a car accident. It was a nightmare."51

[56] The nature of Mr Bardis' assault led the Applicant to believe that he was fighting for his life. In our view his response was reasonable and proportionate to the threat he faced. In circumstances where the physical confrontation was over in a matter of seconds and there is an evidentiary conflict about what happened towards the end of that period there is no sound basis for overturning his Honour's finding that the Applicant was not going on with it but rather was reacting to a real threat to his physical well being. This finding was clearly reasonably open on the evidence.

Policy

[57] The Appellant contended that his Honour had failed to give sufficient weight to the Appellant's policy on fighting. The policy in question is set out in the Appellant's "House Rules". The "House Rules" were included as Attachment 3 to the Tenix Defence Systems Pty Ltd Certified Agreement 1998-2001. It was argued that Tenix's need to maintain the integrity of it's policy constituted, in the circumstances of this case, a valid reason for the termination of the Applicant's employment.

[58] In this context the Appellant relied on the following observation of Moore J in the AWU-FIME case:

[59] Tenix's policy with respect to fighting states:

[60] In the decision subject to appeal his Honour dealt with the company's submission in respect of its policy in the following terms:

[61] We do not discern any error in the manner in which his Honour approached this issue. The Appellant's policy is relevant but it is not determinative of the matter before the Commission. As Sheppard and Heeney JJ observed in Bostik (Australia) Pty Ltd v Gorgevski (No. 1):

[62] In our view his Honour's conclusion that there was no valid reason for the termination of Mr Fearnley's employment was reasonably open to him and does not disclose an error warranting correction on appeal.

Remedy

[63] The Senior Deputy President ordered that Mr Fearnley be reinstated with continuity of employment but no back pay. The Appellant contends that reinstatement should not have been ordered because it was inappropriate to do so.

[64] His Honour's findings in respect of remedy are set out at paragraphs 34-37 of the decision subject to appeal in the following terms:

[65] In McLauchlan's case a Full Bench of the Commission said:

[66] We agree with the above observation. In this case the Appellant - both at first instance and on appeal - relied on the evidence of Mr Sullivan, the Tenix project manager at its Williamstown Shipyard, in support of its contention that reinstatement was inappropriate. When Mr Sullivan was asked what his reaction would be if the Applicant was reinstated he replied:

[67] Two observations may be made in relation to Mr Sullivan's evidence. First, if Mr Sullivan's reference to the conditions of employment at Tenix is taken to be a reference to the "House Rules" then it is an oversimplification to summarise the position with the proposition that "fighting results in dismissal". That is not what the employer's policy says (see paragraph 70 infra). Nor is it consistent with Mr Irving's evidence that it would be harsh to terminate someone who when faced with a threat acted in self defence and assaulted a fellow employee.58 Mr Irving is the Manager - Industrial Relations for Tenix.

[68] Second, it is important to recognise that his Honour's order does not mean that Mr Fearnley has escaped without penalty. The order subject to appeal did not incorporate any component for remuneration lost by Mr Fearnley as a result of the termination of his employment (see s.170CH(4)(b)). As a result the Applicant has suffered a significant financial penalty as a consequence of this incident. The difference between his current earnings and his remuneration as a Tenix employee amounts to some $191.92 per week. Hence the extent of Mr Fearnley's lost remuneration is in excess of $10,000.

[69] In our view his Honour's decision to make an order for reinstatement was reasonably open on the evidence before him and does not disclose an error warranting question on appeal.

Other Appeal Points

[70] The decision we have reached in respect of his Honour's conclusion that there was no valid reason for the Applicant's termination renders it unnecessary for us to deal with the other points advanced by the Appellant. Indeed the Appellant effectively conceded that this was so. In the decision subject to appeal his Honour made it clear that the absence of a valid reason would of itself be sufficient to lead him to conclude that the termination was harsh, unjust or unreasonable. In this context we also wish to make it clear that in our view there is no substance in the Appellant's contention that his Honour failed to take into account the need to ensure that a "fair go all round" is accorded to both the employer and employee concerned.

[71] We note that in determining whether or not a termination of employment is harsh, unjust or unreasonable, the Commission must consider each of the matters referred to in paragraphs 170CG(3)(a) to (e).59 But the Commission is only required to have consideration to such matters in so far as they have application60 or are relevant to the factual circumstances of the particular case.61 If there is no valid reason then paragraph 170CG(3)(b) and (c) have no application. This is because these paragraphs refer to "that reason" and "any reason related to the capacity or conduct of the employee". In the context of s.170CG(3) these references are clearly to the "valid reason" referred to in s.170CG(3)(a). Similarly, unless the termination is related to unsatisfactory performance paragraph 170CG(3)(d) is of no relevance. We find it difficult to conceive of the circumstances in which it could reasonably be said that despite the absence of a valid reason for termination the employee had been accorded procedural fairness and therefore the termination was not "harsh, unjust or unreasonable". As the Full Bench in Steggles Limited v West observed:

[72] In reaching this conclusion we do not wish to be taken to be agreeing with two particular observations made in the decision subject to appeal.

[73] The first concerns his Honour's reliance on the fact that the Applicant was never shown a copy of Mr Formosa's statement during the investigation into the incident. This fact was used to support his Honour's conclusion that the Applicant was not truly given an opportunity to put whatever he wished in answer to the allegations made against him.

[74] In the proceedings before us it was agreed that the Applicant was not shown a copy of Mr Formosa's statement but Mr Addison, on behalf of the Applicant, did not contest the proposition that the substance of what was in the statement was put to the Applicant. In our view that was all that the employer was required to do - that is to put to the Applicant the substance of what was said against him.

[75] We accept the Appellant's submission that in conducting a disciplinary inquiry an employer is not required to adopt the standards applied to a judicial inquiry. In this regard we adopt the following remarks by Heerey J in Schaale v Horscht Australia Ltd:

[76] It is clear from the above extract that what is required is that the employer take reasonable steps to investigate the allegations and give the employee a fair chance of answering them.

[77] The second point relates to his Honour's observations about the attempts by Union delegates to mislead the company as to the true nature of the incident on 10 February 1999. In his regard his Honour said:

[78] We do not wish to be taken to agree with the above observation. In our view the attempt to misdirect the Company's investigation of the incident was a serious matter and should have been accorded more weight in his Honour's consideration of whether the Applicant had been afforded a reasonable opportunity to respond to the allegations made against him. In this context we note that Mr Fearnley was a reluctant participant in the attempt to misdirect the investigation.65

Conclusion

[79] Leave to appeal is not a mere formality and a substantive submission is required if leave is to be granted.

[80] The requirement for an arguable case of either legal error or that the discretion has been miscarried means that the Appellant must demonstrate that their case has a reasonable prospect of success. This requirement is rigorously applied in order to ensure that the standing and purpose of Commission proceedings at first instance are not diminished by automatic or unwarranted access to an Appeal Bench.

[81] We also note that in order to warrant a decision granting leave to appeal more is usually required than simply establishing a case that might have persuaded the Full Bench to exercise the discretion in another way as if the matter was being considered at first instance. In the absence of an arguable case of either legal error or that the discretion was miscarried the Commission would not grant leave to appeal merely to substitute its decision for the decision under appeal.66

[82] We are satisfied that the conclusion reached by the Senior Deputy President in the decision subject to appeal was reasonably open on the material before him. We refuse leave to appeal. We also order that the stay order issued by Vice President Ross on 28 April 2000 [Print S5330] in respect of this matter be set aside.

BY THE COMMISSION:

VICE PRESIDENT

Appearances:

R. Dalton for Tenix Defence Systems Pty Ltd.

M. Addison for K. Fearnley.

Hearing details:

2000.
Melbourne:
March 23.
May 5.

Printed by authority of the Commonwealth Government Printer

<Price code G>

1 Print S3559, 25 February 2000 per Senior Deputy President Williams.

2 See Exhibit B10.

3 Transcript 17 December 1999, p.124 at lines 14-18.

4 Print S3557.

5 Print S3557 at para 32.

6 Print S3557 at para 33.

7 Edwards v Giudice [1999] FCA 1836 per Moore J.

8 (1936) 55 CLR 499 at 504-5; see Construction, Forestry, Mining and Energy Union v Giudice at pp 28-29.

9 (1936) 55 CLR 499 at pp 504-505.

10 (1998) 84 IR 1.

11 (1995) 62 IR 385 at 393.

12 I.138/1993 at p. 9; also see Mobil Oil v Giuffrida, Print N4832, 11 September 1996 per Polites SDP, Duncan DP and Hodder C.

13 Print N4832, 11 September 1996 per Polites SDP, Duncan DP and Hodder C.

14 (1998) 83 IR 102 at 109-110.

15 (1998) 84 IR 1.

16 Exhibit A4 at Appeal Book Tab 7; Exhibit A5 at Appeal Book Tab 14 (attachments TFS1 and TFS2); and Transcript 16 December 1999, pp 12-16 and 25-50.

17 Exhibit B5, attachment TFS7 at Appeal Book Tab 14; Exhibit B8, attachment A12 at Appeal Book Tab 13.

18 Exhibit B5, attachment TFS4 at Appeal Book Tab 14.

19 Exhibit B5, attachment TFS5 at Appeal Book Tab 14.

20 Exhibit B8, attachment AI2 at Appeal Book Tab 13; Transcript 16 December 1999 at pp 62-70.

21 Exhibit B4 at Appeal Book Tab 15; Transcript 16 December 1999 at pp 72-75, 81-89 and 103-104.

22 Print P2322, 28 July 1997 per Ross VP, Drake DP and Cargill C; see further Department of Social Security and Dean Uink, Print P7680, 24 December 1997 per Ross VP, Drake DP and Palmer C at 16-17.

23 Print R4471, 11 May 1999 per RossVP, Polites SDP and Foggo C at paras 44-54.

24 (1990) 171 CLR 167 at 178-179.

25 Exhibit A4.

26 Transcript 16 December 1999, p.14 at lines 18-25; p.33 at lines 9-28 and p.38 at lines 9-10 and 33-36.

27 Transcript 16 December 1999, p.38 at lines 19-23.

28 Transcript 16 December 1999, p.35 at lines 22-29.

29 Transcript 16 December 1999, p.37 at lines 4-5.

30 Transcript 16 December 1999, p.63 at lines 14-15; p.64 at lines 25-26 and p.65 at lines 28-32.

31 Transcript 16 December 1999, p.94 at lines 11-12; p.103 at lines 16-21 and p.105 at lines 4-6.

32 Mr Morgan: Exhibit B2, Transcript 16 December 1999, pp 63-64; Mr Formosa: Exhibit B4, Transcript 16 December 1999, pp 73-74 and 84.

33 Transcript 16 December 1999, p.16 at lines 1-28.

34 Transcript 16 December 1999, p.61 at lines 24-25.

35 Transcript 16 December 1999, p.42 at lines 28-34.

36 Transcript 16 December 1999, p.43 at lines 1-2.

37 Transcript 16 December 1999, p.66 at lines 7-19.

38 Transcript 16 December 1999, p.73 at lines 1-6.

39 Transcript 16 December 1999, p.16 at lines 1-15.

40 Transcript 16 December 1999, p.74 at line 1 and pp 84-85.

41 See the final written submission of the respondent at paragraphs 37-42.

42 Transcript 16 December 1999, p.68 at lines 1-13.

43 Transcript 16 December 1999, p.16 at lines 11-15.

44 Transcript 16 December 1999, p.15 at lines 10-15.

45 Transcript 16 December 1999, p.41 at lines 15-16.

46 Transcript 16 December 1999, p.104 at lines 18-25.

47 Exhibit A5, Transcript 16 December 1999 at pp 20-21.

48 Transcript 16 December 1999, p.82 at lines 2-8.

49 Transcript 16 December 1999, p.83 at lines 23-29 and p.84 at lines 1-7.

50 Transcript 16 December 1999, p.68 at lines 15-26.

51 Transcript 16 December 1999, p.15 at lines 30-32.

52 (1995) 62 IR 385 at 392-393.

53 Exhibit B1.

54 Print S3557.

55 (1992) 36 FCR pt p.29.

56 (1998) 84 IR 1 at 19.

57 Transcript 17 December 1999, p.124 at lines 15-18.

58 Transcript 22 December 1999, p.190 at lines 1-4.

59 Edwards v Giudice and Others (1999) 169 ALR 89, at p.92 per Moore J; King v Freshmore (Vic) Pty Ltd, Print S4213, 17 March 2000 per Ross VP, Williams SDP and Hingley C.

60 Chubb Security Australia Pty Ltd v Thomas, Print S2679, 2 February 2000 per McIntyre VP, Marsh SDP and Larkin C.

61 King v Freshmore (Vic) Pty Ltd.

62 Print S5876, 11 May 2000 per Watson SDP, Williams SDP and Smith C at para 9.

63 (1993) 43 IR 249 at 252; also see Department of Social Security v Uink, (1997) 77 IR 244.

64 Print S3559 at paragraph 19.

65 Transcript 16 December 1999, p.17 at lines 12-25.

66 Corporation of the Catholic Archdiocese of Brisbane v. A.S.U., Print K7698, 19 May 1993 per Moore VP, Keogh SDP and Bacon C: