Restrictions OK
Jurisdiction Employment Relations Authority - Auckland
Reference No [2013] NZERA Auckland 131
Hearing date 28 Mar 2013
Determination date 16 April 2013
Member E Robinson
Representation S Mitchell ; A Schirnack
Location Auckland
Parties Maritime Union of New Zealand v Portpro Inc
Summary PRACTICE AND PROCEDURE – Application for cancellation of union registration under s17 Employment Relations Act 2000 (“ERA”) – Authority found statutory presumption of compliance with ERA at point respondent’s registration as union took place – Found Authority’s discretion under s17(2) ERA to order cancellation of respondent’s registration arose only where respondent’s non-compliance with registration requirements in s14(1) ERA occurred subsequent to fact of registration – Found fact of respondent’s registration meant Registrar of Unions presumed respondent’s rules compliant with s14(1) ERA at time of registration and subsequent amendment to respondent’s rules did not affect presumption – Cancellation of respondent’s registration declined
Abstract Applicant sought cancellation of respondent’s union registration under s17 Employment Relations Act 2000 (“ERA”). Applicant claimed respondent’s rules did not comply with registration requirements of s14(1)(a) ERA at time of respondent’s registration as did not promote members’ collective employment interests. Respondent’s rules amended subsequently to state respondent established to further interests, including collective interests, of respondent’s members. Applicant claimed subsequent amendment of rules did not rectify initial failure to fulfil requirements of s14(1)(a) ERA. Respondent claimed statutory presumption of compliance with s14(1) ERA requirements at time of registration.;AUTHORITY FOUND –;PRACTICE AND PROCEDURE: Section 14(2) ERA clear Registrar of Unions (“Registrar”) entitled to rely upon statutory declaration made by respondent when deciding whether respondent entitled to be registered as union. Once respondent registered as union, certificate of registration conclusive proof under s15(3) ERA of compliance with all requirements of ERA. Statutory presumption of compliance with ERA at point registration of respondent took place. Authority’s discretion under s17(2) ERA to order cancellation of respondent’s registration arose only where respondent’s non-compliance with registration requirements in s14(1) occurred subsequent to fact of registration. Fact of respondent’s registration meant Registrar presumed respondent’s rules compliant with s14(1) ERA at time of registration and subsequent amendment to respondent’s rules did not affect presumption of compliance. Cancellation of respondent’s registration declined.
Result Application dismissed ; Costs reserved
Main Category Practice & Procedure
Statutes ERA;ERA s13(2)(c);ERA s14;ERA s14(1);ERA s14(1)(a);ERA s14(2);ERA s15(2);ERA s15(3);ERA s17;ERA s17(2)
Cases Cited Meat & Related Trades Workers Union of Aotearoa Inc v Te Kuiti Beef Workers Union Inc (2001) 1 NZELR 299
Number of Pages 7
PDF File Link: 2013_NZERA_Auckland_131.pdf [pdf 209 KB]