Labour Court - 2014 February

19 judgments
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19 judgments
Citation
Judgment date
February 2014
Casual workers exceeding six weeks in any four consecutive months become permanent employees under the Labour Act.
Labour law – Casual workers – Conversion to permanent employment after six weeks in any four consecutive months (s 12(3)/12(B)) – Overtime and underpayment claims – Payment in lieu of reinstatement as admission – Labour Act applies to former employment disputes.
27 February 2014
27 February 2014
Review of dismissal fails where the alleged witness was the applicant's own and uncontested documentary evidence supports dismissal.
Labour law – review of disciplinary decision – distinction between review (procedural fairness) and appeal (appropriateness of decision) – failure to call own witness – affidavit evidence – civil standard (balance of probabilities) – undisputed documentary evidence (bank deposits) supporting dismissal.
13 February 2014
The appellant in contempt of a tribunal order must purge that contempt before the Labour Court will hear its appeal.
Labour law – Appeal – Contempt for non‑compliance with tribunal order; s92E(2) Labour Act (appeal does not suspend tribunal decision); "dirty hands" doctrine; Section 85(2) Constitution inapplicable to ordinary appeals; interim relief under s92E(3).
13 February 2014
An arbitrator lacked jurisdiction to quantify allowances not determined in his earlier final arbitral award; the award was set aside.
Labour law – arbitration – jurisdiction and functus officio – finality of arbitral awards – quantification of claims not determined in earlier award – res judicata.
13 February 2014
Contradictions in a witness’s criminal testimony do not automatically invalidate that witness’s evidence in disciplinary proceedings.
Disciplinary law – reliance on witness evidence – inconsistencies in criminal trial testimony – relevance of evidence‑in‑chief – limits on civil review of criminal proceedings – uncertified criminal record extract.
13 February 2014
Failure to lodge heads of argument under Rule 19 warranted striking the matter off the roll.
Civil procedure — Labour Court Rules (SI 59/2006) Rule 19 — Mandatory lodgement of heads of argument — Registrar’s duty to set down matters when heads are not filed — Non-compliance — Agreement between counsel cannot excuse breach — Striking matter off the roll.
13 February 2014
Stay pending appeal granted where applicant showed prima facie success, likely irreparable harm and favorable balance of convenience.
Labour law — stay of execution pending appeal; requirements: prospects of success, irreparable harm, balance of convenience; procedural irregularity (absence of dismissal letter) vs ex tempore verdict.
13 February 2014
Stay of execution refused where employer’s prospects of success were poor and no irreparable harm was shown.
Labour law – stay of execution pending appeal (s92E) – binding retrenchment agreements and contractual bonuses – prospects of success, irreparable harm, balance of convenience.
13 February 2014
Senior employee convicted of corruption and incompetence; dismissal upheld as proportionate abuse-of-trust sanction.
Labour law – disciplinary misconduct – corruption and incompetence – admissions corroborated by independent witness – abuse of position of trust – dismissal as appropriate sanction; procedural complaints more properly addressed by review.
13 February 2014
Dismissal for alleged misappropriation set aside where denial of access to records and audit evidence undermined fairness and proof.
Disciplinary law — fair hearing — denial of access to documents undermining defence; employer’s failure to train acting appointee — relevance to substantive fairness of dismissal; assessment of audit evidence versus disciplinary findings; reinstatement ordered.
13 February 2014
Referral to a Labour Officer after an internal disciplinary determination bypasses the Code's appeal and is incompetent.
Labour law – jurisdiction – section 101(6) Labour Act – applicability where matter is or is liable to be subject to a Code of Conduct (S.I. 15 of 2006) – internal appeal mechanisms must be exhausted – referral for delay, not to challenge an existing determination.
13 February 2014
Appeal dismissed: arbitrator’s factual findings on pension, medical and tax issues did not amount to unfair labour practice or gross misdirection.
Labour law — Appeal from arbitration — standard of review — question of law vs. factual findings — gross misdirection — unfair labour practice allegations concerning pension calculation, unpaid arrears, medical aid non-remittance and ZIMRA/tax filings.
13 February 2014
Failure to account for mastered council funds justified dismissal for theft/misappropriation; appeal dismissed with costs.
Labour law — Misconduct and dismissal — Theft/misappropriation of employer funds — Responsibility of employee who 'masters' cash and fails to account — Proof of essential elements; procedural fairness in charging.
13 February 2014
Court refused default judgment for late response where documents lacked case number and insisted appeal be decided on merits by another judge.
Labour procedure — default judgment — failure to file notice of response timeously — service without case number — discretion to apply rules flexibly — Rule 26 invoked to decide appeal on merits — application from the bar improper.
13 February 2014
Arbitral award set aside; back pay to be re-quantified using appropriate currency conversion and 18 months' compensation.
Labour law – constructive dismissal – back pay and mitigation of damages; currency nominalisation – conversion of Z$ to US$ after multi-currency adoption; use of Reserve Bank exchange rates; remittal for re‑quantification; 18 months compensation.
13 February 2014
Applicant's review dismissed for failure to exhaust internal remedies and failing to show prejudice from alleged irregularities.
Labour law — review — necessity to exhaust internal remedies before court review; procedural irregularities; mitigation; requirement to prove prejudice; compliance with procedural rules.
13 February 2014
Court dismissed appeal against dismissal for misconduct: no requirement for oral evidence and delay did not vitiate proceedings.
Labour law — disciplinary proceedings — oral evidence not mandatory under employer's Code — procedural delay caused by appellant's addendum — no proven bias — standard of proof: balance of probabilities — legal representation not required in informal workplace disciplinary procedure.
13 February 2014
Wrongfully dismissed employee entitled to back pay, but damages reduced for failure to mitigate employment losses.
Labour law – wrongful dismissal – effect of quashing dismissal as reinstatement – back pay from date of dismissal to reinstatement order – damages for period to find alternative employment – duty to mitigate and reduction of award for failure to mitigate.
13 February 2014