Restrictions OK
Jurisdiction Employment Relations Authority - Auckland
Reference No AA 238/06
Hearing date 30 Jun 2006
Determination date 11 July 2006
Member A Dumbleton
Representation D Orgab ; C Patterson
Location Auckland
Parties Harcombe v Bakers Delight (NZ) Ltd
Summary PARENTAL LEAVE – Applicant alleged respondent breached Parental Leave and Employment Protection Act 1987 (PLEPA") by appointing permanent replacement to her position while she was on parental leave - Applicant not consulted about appointment and unaware of situation until three months before intended return - Applicant lodged PLEPA complaint with Authority and parties ordered to mediation – Respondent’s counsel accepted mediation date, unaware respondent’s manager unavailable – Applicant attended mediation two weeks before intended return to work but no appearance for respondent – Mediator phoned respondent’s counsel who advised employment problem had arisen because of misunderstanding and applicant able to resume original role – Mediator relayed message to applicant – Applicant tentatively accepted offer of reinstatement but asked Authority to continue hearing application for compensation and costs – Respondent claimed as applicant not dismissed remedies not available – PLEPA breached when another person was appointed to position applicant held before going on parental leave - Applicant was in effect dismissed from position – Respondent aware of mistake one month before applicant due to return but failed to take timely steps to advise her and correct error – Respondent’s failure to undertake mediation or similar process to expeditiously resolve complaint breached s64 PLEPA – Respondent’s failure to consult applicant about new appointment breached duty of good faith in s4 Employment Relations Act 2000 – Applicant’s reinstatement did not wipe away breach of PLEPA or harm it caused – Situation exacerbated by failure to act proactively, responsibly and communicatively as required by duty of good faith – Remedies – Compensation awards under s65(c) PLEPA were not to serve function of penalty - Applicant entitled to compensation for harm suffered – Leave reserved to apply to re-open complaint and personal grievance if necessary – Marketing Business Consultant"
Result Application granted ; Compensation ($3000)(s65(c) PLEPA) ; Orders accordingly ; Costs reserved
Statutes ERA s4;Parental Leave and Employment Protection Act 1987 s49(1)(c);Parental Leave and Employment Protection Act 1987 s64;Parental Leave and Employment Protection Act 1987 s65(c)
Cases Cited Ter Harr v Elliot Cotton Associates [1993] 1 ERNZ 371
Number of Pages 6
PDF File Link: aa 238_06.pdf [pdf 83 KB]