PR923358

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AUSTRALIAN INDUSTRIAL RELATIONS COMMISSION

Workplace Relations Act 1996

s.45 appeal against decision

PR917063 issued by Commissioner Cribb on 23 April 2002

J.P. Dundovich

(C2002/2586)

s.170CE Application for relief re termination of employment

J. Dundovich

and

P&O Ports

(U2001/2311)

VICE PRESIDENT ROSS

 

DEPUTY PRESIDENT HAMILTON

 

COMMISSIONER EAMES

MELBOURNE, 8 OCTOBER 2002

Termination of employment - appeal - appeal filed out of time - extension of time granted despite absence of satisfactory explanation - short period of time - no prejudice to respondent - meritorious appeal. Failure to take account of a material consideration - appellant had a compensable work related injury at the time of termination - leave granted - appeal upheld - termination harsh, unjust and unreasonable - remitted for determination of remedy.

DECISION

Introduction

[1] This decision deals with an appeal by Mr J.P. Dundovich (the appellant) under s.45 of the Workplace Relations Act 1996 (the WR Act) against the decision made by Commissioner Cribb on 23 April 20021 arising out of an application for relief filed by Mr Dundovich in respect of the termination of his employment with P&O Ports Limited (P&O).

[2] In the decision subject to appeal the Commissioner found that the termination of Mr Dundovich's employment was "not harsh, unjust or unreasonable" and dismissed his application.

[3] We propose to set out the relevant background facts before turning to the decision subject to appeal.

Background

[4] On 19 February 1990 Mr Dundovich commenced full-time, permanent, employment with P&O at the company's West Swanson Container Terminal (the Terminal) in Melbourne. He worked as a crane driver between 1990 and 1997, primarily driving a portainer. Between October 1997 and July 1999 Mr Dundovich was employed as a foreman. Between 29 July 1999 and 13 June 2000 he worked as a relief foreman.

[5] In 1999 P&O sought to introduce a new enterprise bargaining agreement at the Terminal to facilitate structural change. The Maritime Union of Australia (the MUA) and P&O were unable to reach an agreement. P&O successfully applied to terminate a bargaining period which had been initiated by the MUA. Following the termination of the bargaining period the Commission proceeded to make an award pursuant to s.170MX of the WR Act, known as the P&O Ports West Swanson Container and Ro Ro Terminal Enterprise Award 19992 (the s.170MX Award).

[6] The s.170MX Award came into operation on 2 August 1999. Appendix 3 to the award identifies the manning levels at the Terminal and the proposed number of employees to fill each classification within the restructured workforce. The number of foremen required following the restructure was 24, including four "charge" foremen. Previously there had been 45 foremen in total. The s.170MX Award also introduced new rostering arrangements, which did not suit Mr Dundovich's personal circumstances.

[7] On 29 July 1999, Mr Sammut, P&O's Human Resources Manager for the Terminal, posted a document on the foreman's mess room notice board. The document served to notify all employees of their likely function once the s.170MX Award came into operation on 2 August 19993. Under the proposed new arrangements Mr Dundovich was to work as a portainer driver rather than as a foreman. But he would still be paid as a foreman pursuant to an agreement between the MUA and P&O. On 2 August 1999 Mr Dundovich lodged a personal grievance on the grounds that during the restructuring of operations at the Terminal he "was overlooked for the position of permanent Foreman"4.

[8] To facilitate the restructuring process P&O had planned to introduce a new computer system (the NAVIS computer system) in September or October 1999 to enable the Terminal to operate effectively with only 24 foremen. But the NAVIS system was not fully operational until April or May 2000. In the absence of this system P&O operated with a number of "relief foremen" as an interim measure. Mr Dundovich worked as a relief foreman until 24 May 2000.

[9] Clause 8.4 of the s.170MX Award states:

[10] Mr Dundovich was competent to perform the duties of foreman, straddle driver and portainer driver.

[11] Mr Dundovich began to feel physically and mentally unwell after the introduction of the new work arrangements in October 1999. His condition deteriorated in early 2000 and he commenced taking prescribed medication for depression in May 2000.

[12] In March 2000 a position for a permanent crane foreperson was advertised. Mr Dundovich applied for the position, but was unsuccessful. He subsequently lodged a personal grievance in relation to his non-selection.

[13] On 10 May 2000, Mr Hindle, the Operations Resource Manager at the Terminal, wrote to Mr Dundovich in the following terms:

[14] Later in May 2000 Mr Sammut became aware that Mr Dundovich was taking prescribed medication for depression. He decided that it would be appropriate for Dr David Ho, P&O's doctor, to examine Mr Dundovich and assess his fitness for work. A copy of Dr Ho's report is set out at Annexure `SS-13' to Exhibit R2. Dr Ho's report concludes in these following terms:

[15] On 13 June 2000 a meeting was scheduled to discuss Mr Dundovich's personal grievance. Mr Sammut had resolved to discuss Dr Ho's report with Mr Dundovich at that meeting. At some point during the meeting Mr Hindle told Mr Dundovich that he had a serious concern regarding his ability to operate machinery while on medication. Mr Dundovich was sent home on full pay. Mr Hindle told him that he could not resume work until P&O had ascertained exactly what his condition was and then he could participate in a return to work program. Later that day Mr Dundovich filed a workers' compensation claim.

[16] On 14 June 2000 Mr Sammut sent Mr Dundovich a letter advising him that his personal grievance had been unsuccessful6.

[17] In July 2000 P&O received a certificate from Mr Dundovich's doctor stating that he could return to work on alternate duties. A copy of the certificate is set out at Annexure 17 to Exhibit R2.

[18] On 26 July 2000 a meeting took place between Messrs Hindle, Cushion, Dundovich and Colasacco (Operations Superintendent, Systems for the Terminal). The meeting ended on the basis that Mr Dundovich would consult his general practitioner to provide a medical clearance for him to return to work7.

[19] At some point in July 2000 Mr Dundovich's workers' compensation claim was rejected by CGU, P&O's insurers, on the basis that the injury was not work related and that the steps taken by P&O in relation to Mr Dundovich's employment were reasonable. Mr Dundovich commenced proceedings for the payment of weekly payments and medical and other like expenses pursuant to the Accident Compensation Act 1985 (Vic).

[20] Since August 2000 Mr Dundovich has received treatment from Dr Samir Ibrahim, a psychiatrist.

[21] On 19 October 2000 Holding Redlich wrote to P&O alleging that P&O had discriminated against Mr Dundovich on the basis of his disability, in contravention of s.14 of the Equal Opportunity Act 1995 (Vic)8. P&O replied to Holding Redlich on 21 November 2000 and advised that Mr Dundovich could resume work when P&O "receives medical advice that he is capable of returning to work in his primary role of straddle driver"9.

[22] On 23 November 2001 a WorkCover conciliation conference took place in relation to Mr Dundovich's workers' compensation claim. The matter was not resolved at conciliation.

[23] In December 2001 the MUA notified the Commission of a dispute in relation to Mr Dundovich's situation. A conciliation conference took place before Commissioner Raffaelli on 20 December 2001 at which the parties reached an agreement in relation to Mr Dundovich's possible return to work. Details of the agreement are as follows:

[24] Pursuant to the agreement medical reports were received from Drs Ibrahim and Miller. Dr Ibrahim's report concluded in the following terms:

[25] P&O sought an opinion from Dr Miller whose report concluded that:

[26] Messrs Sammut and Hindle gave evidence to the effect that having read the medical reports they were not convinced that Mr Dundovich was fit to return to work. Despite their reservations they agreed to try a return to work program.

[27] On 15 March 2001 a meeting took place involving Messrs Sammut and Hindle with Ms Mazic from P&O, and Mr Cushion, Mr Dundovich and Mr Walvisch, a solicitor from Holding Redlich. The purpose of the meeting was to discuss Mr Dundovich's future at P&O in light of the medical reports. The parties agreed to participate in a two week return to work plan, the purpose of which was to desensitise Mr Dundovich for straddle driving.

[28] A copy of the agreed return to work program is set out at Annexure 8 to Exhibit A1.

[29] On 30 March 2001 a meeting was held to review Mr Dundovich's progress. Messrs Sammut, Hindle, Cushion and Dundovich and Ms Mazic attended the meeting. When asked whether he could drive the straddle Mr Dundovich said that he thought he would eventually be able to, but would need more time13. The P&O representatives left the meeting to speak to Mr Doug Schultz, Manager Container Handling.

[30] Messrs Sammut and Hindle told Mr Schultz that Mr Dundovich could not drive a straddle and would not be able to for the foreseeable future, and in the circumstances it was appropriate to dismiss him.

[31] Mr Schultz agreed that termination was appropriate.

[32] The P&O representatives returned to the meeting room and Mr Hindle informed Mr Dundovich that his employment had been terminated because he was unable to fulfil his duties as a straddle driver. Mr Dundovich subsequently received a letter from Mr Schultz, dated 30 March 2001, in the following terms:

[33] On 20 July 2001 Magistrate Jones handed down his decision in respect of Mr Dundovich's application claiming weekly payments of compensation from 13 June 2000, together with medical and like expenses pursuant to the provisions of the Accident Compensation Act 1985. Magistrate Jones upheld Mr Dundovich's claim. A copy of his reasons for decision is set out at Annexure 6 to Exhibit A1.

[34] In August 2001 Dr Ibrahim certified that Mr Dundovich was expected to be fit to return to his normal duties from 18 August 200115.

[35] We now turn to the decision subject to appeal.

Decision at First Instance

[36] Mr Dundovich filed his application for relief in respect of the termination of his employment, pursuant to s.170CE of the WR Act. The application was heard by Commissioner Cribb on 18 September, 11 October and 12 December 2001. On 23 April 2002 the Commissioner handed down her reasons for decision.16

[37] The principal findings in the decision at first instance in relation to whether the termination of Mr Dundovich's employment was harsh, unjust or unreasonable are dealt with below by reference to the provisions of s.170CG(3).

Section 170CG(3)

[38] The Commissioner determined that there was a valid reason for the termination of the applicant's employment.17 In this context the Commissioner made the following findings:

Section 170CG(3)(b)

[39] During the meeting on 30 March 2001 the applicant was notified of the reason for his termination, that is because he was unable to drive the straddle at the end of the return to work program and that it was unlikely that he would be able to do so in the foreseeable future.22

Section 170CG(3)(c)

[40] The Commissioner accepted that at the meeting on 15 March 2001 Mr Hindle told the applicant, "in clear terms" that if he was unable to drive the straddle at the end of the return to work program his employment would be terminated. On this basis the Commissioner concluded that the applicant had been "put on notice" regarding the possibility of being terminated.23

[41] In relation to the meeting on 30 March 2001 the Commissioner said:

[42] The Commissioner concluded that the applicant had been given an opportunity to respond to the reason for his termination.25

[43] In relation to s.170CG(3)(d) the Commissioner concluded that having regard to the circumstances of the matter the provision did not apply.26

Section 170CG(3)(e)

[44] The applicant raised a number of other matters which were said to be relevant to the determination of whether the termination of his employment was harsh, unjust or unreasonable. In relation to the matters raised the Commissioner made the following findings:

[45] The Commissioner concluded her decision in the following terms:

Out of Time

[46] The notice of appeal was lodged on 21 May 2002. Rule 11(2)(a) of the Commission's rules provides that an appeal must be instituted "before the end of 21 days after the date of the . . . decision appealed against." The decision subject to appeal was made on 23 April 2002. Hence the appeal was lodged some seven days outside of the prescribed time period.

[47] Rule 11(2)(c) confers power on a Full Bench of the Commission to extend the time within which an appeal is to be lodged. In Stevenson-Helmer v Epworth Hospital31 the Commission made the following observations about the exercise of the power in Rule 11(2)(c):

[48] The authorities cited in the above extract provide that the following matters are relevant to the exercise of the Commission's discretion under Rule 11(2)(a):

[49] We propose to deal with each of these matters in turn.

Reason for the Delay

[50] The appellant's explanation for the delay in instituting the appeal is set out in the Appellant's submissions. The relevant part of the submissions states:

[51] It is apparent from Mr Dundovich's affidavit of 21 May 2002 that his explanation for the delay in lodging the appeal is:

[52] Further, Mr Dundovich's affidavit shows that at least from 9 May 2002 (some five days before the expiry of the time period for the lodgement of the appeal) he knew about the time limit that applied.33

[53] Counsel for the respondent dealt with this issue at paragraphs 18 and 21 of Exhibit R1:

[54] We agree with the respondent on this point. We are not persuaded that the appellant has advanced a satisfactory reason for the delay in instituting the appeal.

Length of the delay

[55] The length of the delay is short, being only seven days.

Prospects of success on appeal

[56] We are satisfied that the appellant has a strongly arguable case on both the question of leave to appeal and on the substantive appeal.

Prejudice to the respondent

[57] There are no developments after the time for lodgement has expired that would give rise to additional prejudice to the respondent.

Conclusion

[58] We have had regard to each of the matters set out at paragraph 48 of this decision. Despite the absence of a satisfactory explanation for the delay we have decided to grant the extension of time sought. The absence of a satisfactory explanation must be weighed against the short period of the delay, the absence of prejudice to the respondent occasioned by the delay and the injustice which would accrue to the appellant in being denied an extension on a meritorious appeal.

[59] Pursuant to Rule 11(2)(c) we will extend the time period for the lodgement of the appeal until 21 May 2002.

The Appeal

[60] The appellate jurisdiction conferred on us by s.45(1)(b) 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.34

[61] The nature of an appeal under s.45 of the WR Act was the subject of consideration by the High Court of Australia most recently in Coal and Allied Operations Pty Ltd v Australian Industrial Relations Commission35 (Coal & Allied). Gleeson CJ, Gaudron and Hayne JJ, in a joint judgment, said:

[62] The types of error that may constitute grounds for review of a discretionary decision of the kind here under consideration were re-stated in Coal & Allied in the following way:

[63] We now turn to deal with the particular points advanced by the appellant. The grounds set out in the notice of appeal are as follows:

[64] The thrust of the appellant's submissions were directed the Commissioner's conclusion that there was a valid reason for the termination. At paragraphs 54 to 56 of the decision subject to appeal the Commissioner said:

[65] The appellant contends that this part of the Commissioner's reasoning was erroneous as the Commissioner failed to take into account a material consideration - namely that at the time of the decision to terminate Mr Dundovich's employment he had a work related stress condition and was eligible for compensation pursuant to the Accident Compensation Act 1985 (Vic) (the AC Act). By reason of the existence of a workplace injury Mr Dundovich had rights, and his employer had obligations, under the AC Act, particularly under s.122 of that act.

[66] Section 122 of the AC Act provides:

[67] In the twelve months following his injury Mr Dundovich had only partial capacity for work, hence it is argued that in accordance with s.122(1)(b) of the AC Act P&O were obliged to provide him with `suitable employment'. Section 5 of the AC Act defines `suitable employment' in these terms:

[68] Counsel for the appellant contended that the two week return to work program implemented by P&O, which formed the basis of the decision to terminate Mr Dundovich's employment, was unrealistic and unreasonable. The following points were made in support of that position:

[69] It was argued that P&O had failed in its obligation under s.122(1)(b) of the AC Act to explore what suitable employment may have been available to Mr Dundovich given the range of skills he possessed. In terminating Mr Dundovich's employment just nine months after he became entitled to weekly payments of compensation P&O has acted prematurely as it had an obligation to keep the employment open for a period of twelve months.

[70] In advancing the above submissions the appellant made it clear that they were not intended to make the Commission the de facto enforcer of s.122. It was acknowledged that s.122 was a penal provision which did not give rise to a personal right of action in the event of it breach38 but did expose an employer, who failed to comply with its obligations, to significant monetary penalty. Rather, P&O's failure to meet its obligations under the AC Act were said to "shine a torch" on various matters that are relevant as to whether an employee has had a "fair go" including:

[71] Further, the appellant accepts that the Magistrate's Court's judgment itself was not a circumstance in existence at the time of Mr Dundovich's termination, that would be a chronological impossibility. But that judgment is said to be significant because it was declaratory of the circumstance which existed at the time of the decision to terminate - namely that Mr Dundovich had a work-related injury which gave him certain rights under s.122 of the AC Act. In this context the appellant submitted that:

[72] The appellant contended that the error in the decision subject to appeal was that the Commissioner conflated the circumstance of the Magistrate's Court's judgment of 20 July 2001 and the circumstance of the existence of a compensable workplace injury although the two are distinct circumstances.

[73] In reply the respondent relied on the submissions it put at first instance with respect to the issue of whether there was a "valid reason" for the termination of Mr Dundovich's employment.40 In addition the respondent advanced the following points in response to the appellant's submissions on this issue:

[74] We now turn to consider the submissions directed at whether there was a valid reason for the termination of Mr Dundovich's employment.

[75] The approach of the Commission to this issue was discussed in Australia Meat Holdings Pty Ltd v McLauchlan.41 In that case a Full Bench of the Commission concluded:

[76] The central issue in this case concerns the nature of the "circumstances in existence when the decision to terminate" Mr Dundovich's employment was made. At paragraph 54 of the decision subject to appeal the Commissioner identifies the following facts that were in existence at the relevant time:

[77] The Commissioner went on to reject the proposition that the judgment of Magistrate Jones given on 20 July 2001 was a circumstance in existence at the time the decision was taken to terminate Mr Dundovich's employment.

[78] We think that the Commissioner erred in her consideration of Magistrate Jones' judgment. The effect of that judgment was to determine that since 13 June 2000 Mr Dundovich had an entitlement to weekly payments of compensation pursuant to the AC Act. The Magistrate's judgment did not bring into existence the compensable injury, rather, it confirmed it as a fact in existence at the time of dismissal. We accept the appellant's submission that the Magistrate's decision was declaratory of the circumstances which existed at the time of the decision to terminate Mr Dundovich's employment.

[79] In her consideration of the circumstances in existence at the relevant time the Commissioner failed to have regard to a material consideration, that is, at the time of the decision to terminate Mr Dundovich's employment he had a work related injury and was entitled to weekly payments of compensation pursuant to the AC Act. That this fact was not known to the employer at the time of the decision to terminate Mr Dundovich's employment is not determinative. As the Full Bench in McLauchlan's case observed, facts which existed at the time of dismissal but only come to light after the decision may render a termination of employment harsh, unjust or unreasonable.

[80] Even if we are wrong about the views expressed above and it is appropriate to have regard to the knowledge that the employer had at the time of the termination we would have reached the same conclusion. At the time of the termination the employer was aware that the applicant considered himself entitled to weekly payments of compensation, and despite the risk that s.122 would be later found to apply the employer decided to terminate Mr Dundovich's employment. In our view we should have regard to the circumstances of the employer's actions, and give weight to it. It may be given less weight than if the employer took action in circumstances where the employee was actually in receipt of weekly payments, and therefore in full knowledge that the obligations under s.122 were in operation, but nevertheless it must be given some weight.

[81] The Commissioner's failure to have regard to the fact that Mr Dundovich had a work related compensable injury at the time of the decision to terminate his employment is an error in the Commissioner's decision making process. On this basis we have decided to grant leave to appeal.

[82] We now turn to consider for ourselves the question of whether the termination of Mr Dundovich's employment was harsh, unjust or unreasonable.

[83] Section 170CG(3) of the Act provides:

[84] It is clear from both the language and structure of s.170CG(3), and the statutory context in which it appears, that the section requires the Commission to consider each of the matters referred to in paragraphs 170CG(3)(a) to (e). Not only must the matters be considered but the words "have regard to" signify that each must be treated as a matter of significance in the decision making process. But the Commission is only required to have consideration to such matters in so far as they have application43 or are relevant to the factual circumstances of the particular case.44

[85] We turn first to the question of whether there was a valid reason for the termination of Mr Dundovich's employment.

[86] Mr Dundovich's employment was terminated after he had participated in a two week return to work program, the purpose of which was to desensitise him to straddle driving. We accept that Mr Dundovich and his representatives did not object to the return to work program and that at the meeting on 15 March 2001 they were told (by Mr Hindle) that if at the end of the two week program Mr Dundovich was not able to work on the straddle then his employment would be terminated.45

[87] We are not satisfied that there was a valid reason for the termination within the meaning of s.170CG(3)(a). Mr Dundovich was suffering from a work related injury at the time of the decision to terminate his employment. We accept the proposition advanced on behalf of the appellant that the scheme of the AC Act casts an obligation on employers to assist an injured worker to return to work and to assist in their rehabilitation. This is evident from both the objects of that act and the terms of s.122. Further, as Hamilton DP observed in Beames v BDRP Falconer Pty Ltd:

[88] In our view P&O did not do enough to assist Mr Dundovich to return to work. We are not persuaded by the reasons advanced on behalf of the respondent as to why the company acted when it did.47 Having regard to all of the circumstances we think that the company acted too quickly in moving to terminate Mr Dundovich's employment.

[89] If there is no valid reason then in our view paragraphs 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).48 Similarly, unless the termination is related to unsatisfactory performance paragraph 170CG(3)(d) is of no relevance.

[90] In Chubb Security Australia Pty Ltd v John Thomas a Full Bench expressed the Commission's obligations under s.170CG(3) in the following way:

[91] If we are wrong about the relevance of paragraphs 170CG(3)(b), (c) and (d) to the matter before us and we assume that the termination was procedurally fair those circumstances would not affect the result in the context of the matter before us. Indeed 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:

[92] We have had regard to matters referred to s.170CG(3) insofar as they are relevant to the factual circumstances of the application before us. We have concluded that the termination of Mr Dundovich's employment was harsh, unjust and unreasonable. Accordingly we have decided to uphold the appeal and quash the Commissioner's decision.

[93] In view of the conclusion we have reached in relation to the `valid reason' ground it is unnecessary for us to deal with the other grounds of appeal advanced.

Conclusion

[94] In failing to take account of the fact that at the time of the decision to terminate Mr Dundovich's employment he had a compensable work related injury the Commissioner failed to take into account a material consideration. In doing so the Commissioner erred in the exercise of her discretion.

[95] For the reasons given we grant leave to appeal, uphold the appeal and quash the Commissioner's decision.

[96] We have concluded that the termination of Mr Dundovich's employment was harsh, unjust and unreasonable. We have decided to remit the matter to Deputy President Hamilton pursuant to s.45(7)(c) to determine the question of remedy after providing the parties with a further opportunity to be heard. We would encourage the parties to meet and confer with a view to reaching a settlement of this matter.

BY THE COMMISSION:

VICE PRESIDENT

Appearances:

M. Champion of counsel for the appellant.

R. Dalton for the respondent.

Hearing details:

2002.

Melbourne:

July 16.

Printed by authority of the Commonwealth Government Printer

1 Print PR917063.

2 Print R7695, 29 July 1999.

3 See Exhibit R2 at paragraphs 27-29 and Annexure `SS-2'.

4 Annexure `SS-4' to Exhibit R2.

5 See Annexure `SS-8' to Exhibit R2.

6 See Annexure `SS-16' to Exhibit R2.

7 See Exhibit R6 at paragraph 39 and Attachment RMH 2 to Exhibit R2.

8 See Annexure `SS-18' to Exhibit R2.

9 See Annexure `SS-19' to Exhibit R2.

10 See Annexure `SS-20' to Exhibit R2.

11 See Annexure `SS-22' to Exhibit R2.

12 See Annexure `SS-24' to Exhibit R2.

13 See Exhibit A1 at paragraph 36

14 See Annexure 9 to Exhibit A1.

15 See Annexure 7 to Exhibit A1.

16 Print PR917063, 23 April 2002.

17 Print PR917063 at paragraph 50.

18 Print PR917063 at paragraph 49.

19 Print PR917063 at paragraphs 49 and 50.

20 Print PR917063 at paragraphs 49 and 50.

21 Print PR917063 at paragraphs 55 and 56.

22 Print PR917063 at paragraphs 57 - 60.

23 Print PR917063 at paragraph 63.

24 Print PR917063 at paragraph 64.

25 Print PR917063 at paragraph 65.

26 Print PR917063 at paragraph 66.

27 Print PR917063 at paragraph 68.

28 Print PR917063 at paragraph 68.

29 Print PR917063 at paragraph 71.

30 Print PR917063 at paragraph 72.

31 Print T2277, 19 October 2000 per Ross VP, Acton SDP and Simmonds C.

32 Exhibit A1 at paragraph 6.

33 See paragraphs 11 and 12 of Mr Dundovich's affidavit of 21 May 2002.

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

35 [2000] HCA 47.

36 [2000] HCA 47 at paragraph 17.

37 [2000] HCA 47 at paragraph 21.

38 See Gardiner v State of Victoria [1999] VSCA 100, 2 July 1999.

39 Exhibit A1 at paragraph 40.

40 See paragraphs 2374 - 2541 of the proceedings at first instance.

41 (1998) 84 IR 1.

42 (1998) 84 IR 1 at 14.

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

44 King v Freshmore (Vic) Pty Ltd, Print L4213, 17 March 2000 per Ross VP, Williams SDP and Hingley C.

45 Transcript, 18 September 2001 at paragraphs 750 to 758.

46 PR916075, 28 March 2002 at paragraph 28.

47 Transcript, 16 July 2002 at paragraphs 192 - 225.

48 Tenix Defence Systems Pty Ltd v Fearnley, Print S6238, 22 May 2000 per Ross VP, Polities SDP and Smith C; Crozier v Palazzo Corporation Pty Limited t/as Noble Park Storage and Transport (2000) 98 IR 137 at paragraph 64.

49 Print S2679.

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