Restrictions OK
Jurisdiction Employment Relations Authority - Wellington
Reference No WA 41/07
Hearing date 26 Jan 2007
Determination date 15 March 2007
Member G J Wood
Representation A Millar ; P Drummond
Location Wellington
Parties Lauchlan v Keegan Contractors Ltd
Summary PRACTICE AND PROCEDURE – Admissibility of evidence – Respondent requested applicant attend mediation – Parties attended mediation – Applicant made allegations about what respondent’s managing director (“MD”) said at mediation – If allegations of what MD said true, applicant’s later evidence (about advice he sought of representative) would not have occurred – Found, as matter of fact, claims about what happened at mediation did not occur - Preferred MD’s evidence that said nothing at mediation constituting grounds for breaching confidentiality – Approach consistent with Jesudhass v Just Hotel Ltd (cited below) – Applicant could establish other matters from MD’s behaviour leading up to mediation, fact of mediation, and events after mediation – While finding resolved issue Authority addressed whether what occurred at mediation not for purposes of mediation and/or for purposes of settling litigation or potential litigation – Initiative to formally address employment issues through mediation unusual - Did not mean initiative unacceptable per se or protections of mediation disregarded – Had events taken place outside mediation “without prejudice” privilege could not have applied – Authority found Court’s phrase in Jesudhass v Just Hotel Ltd “for the purposes of mediation” reflected common law requirement communications genuinely be for purpose of settling litigation or potential litigation before confidentiality applied – Authority found Court not holding had to be litigation or potential litigation before confidentiality could apply - Statutory protection akin to common law – However, prerequisites not same – Considered Jesudhass v Just Hotel Ltd concluded parties engaging in mediation to deal with issue in employment relationship were acting for purposes of mediation - All actions taken for purposes of mediation – Certain evidence inadmissible - Ordered documents be altered
Result Question answered in favour of respondent ; Orders accordingly ; Costs reserved
Main Category Practice & Procedure
Statutes ERA s143(b), ERA s143(c), ERA s143(d),
Cases Cited Bayliss Sharr and Hansen v McDonald unreported, Couch J, 7 December 2006, CC 12/06;Jesudhass v Just Hotel Ltd [2006] ERNZ 173
Number of Pages 6
PDF File Link: wa 41_07.pdf [pdf 26 KB]