Restrictions OK
Jurisdiction Employment Relations Authority - Auckland
Reference No AA 424/10
Hearing date 29 Jun 2010
Determination date 29 September 2010
Member A Dumbleton
Representation M Ryan ; G Stone
Location Auckland
Parties Butterworth v TBA Communications Ltd
Summary UNJUSTIFIED DISADVANTAGE – UNJUSTIFIED DISMISSAL – Redundancy – Parties acknowledged applicant part time – However, when applicant began working at least 25 hours per week parties discussed need for respondent to have full time position – Subsequently respondent purported to disestablish applicant’s part time position – Applicant provided one months notice and advised full time position would be advertised – Applicant claimed redundancy not genuine and fair process not followed – Authority previously declined application for interim reinstatement – Authority noted employee did not have right to continued employment if greater efficiency goal of employer – Found restructuring driven by commercial imperatives – Found decision not based on anything such as applicant’s conduct or performance personal to applicant as holder of position at time – Found sufficient grounds to justify as decision available to fair and reasonable employer – Found applicant given reasonable opportunity to consider proposal and respond during further discussions which occurred – Found no dispute respondent encouraged applicant to apply for position by indicating she had strong chance of being successful – Found respondent reasonably believed applicant had not given unqualified acceptance to work full time hours, because applicant wished to retain “flexibility” – Found applicant was unjustifiably disadvantaged by respondent’s action of not granting request for copy of employment agreement intended to vary part time position held – Found bargaining which took place between parties carried out in breach of s63A(2) Employment Relations Act 2000 and therefore way employer acted not justifiable – Found failure to commit intended variation of applicant’s individual employment agreement to writing and provide copy led to situation of uncertainty between parties as to agreement – Found situation which developed cost applicant opportunity to try and negotiate precisely undefined “flexibility” applicant had sought as well as negotiate over salary for full time position – Found grievance not one of unjustified dismissal, however, failure amounted to unjustified disadvantage – Remedies – No contributory conduct – Found withholding consent to redeployment through variation of EA not matter of fault or blame – Question to what extent loss and harm caused by justified redundancy dismissal and reaction to pending loss of employment – Found applicant lost wages caused by genuine redundancy – No order for reimbursement of lost wages – Found $1,000 compensation appropriate for distress caused to applicant – Mac Operator
Result Application dismissed (Dismissal) ; Application granted (Disadvantage) ; Compensation for humiliation etc ($1,000) ; Costs reserved
Main Category Personal Grievance
Statutes ERA s103A;ERA s62A(2);ERA s63A(2);ERA s63A(1)(e);ERA s65;ERA s65(2)(a)
Cases Cited Butterworth v TBA Communications Ltd unreported, A Dumbleton, 23 Jun 2009, AA 201/09;Simpsons Farms Ltd v Aberhart [2006] 1 ERNZ 825;Telecom New Zealand Limited v Nutter [2004] 1 ERNZ 315;Waitakere City Council v Ioane [2004] 2 ERNZ 194
Number of Pages 11
PDF File Link: aa 424_10.pdf [pdf 37 KB]