Restrictions OK
Jurisdiction Employment Relations Authority - Auckland
Reference No [2011] NZERA Auckland 267
Hearing date 20 Jun 2011
Determination date 21 June 2011
Member D King
Representation D Erickson ; G Stone
Location Auckland
Parties Transpacific Industries Group (NZ) Ltd v Harris and Anor
Other Parties Smart Environmental Ltd
Summary INJUNCTION – RESTRAINT OF TRADE - Application for injunctive relief restraining first respondent (“H”) from working for competitor or approaching or soliciting H’s customers – Employment Court (“EC”) previously held restraint of trade clause preventing H from working for competitor for three months (“three month clause”) arguably unenforceable – EC held restraint clause preventing H from soliciting or approaching applicant’s clients arguably reasonable – Applicant claimed modifying competitor definition in three month clause would address EC’s concerns - H advised applicant considering employment offer from second respondent (“SEL”) and confirmed resignation same day – Applicant claimed H had significant access to confidential information including products, pricing and contracts – Applicant requested H reveal identity of new employer - Applicant sent H statutory declaration requiring H to confirm would comply with employment agreement – As applicant refused to provide legal advice H did not sign declaration – Applicant claimed H attempted to solicit business from applicant’s client – Applicant refused H and SEL’s offer would provide undertaking would not solicit clients H had previously dealt with - Two of H’s clients terminated contract with applicant after approached by H – Applicant claimed Authority should consider particular factual setting despite EC’s finding three month clause arguably unenforceable – Authority found three month clause anti-competitive, unreasonable and unenforceable even taking into account applicant’s proposed modifications – Found clients approached by H not those H had dealt with when employed by applicant – Found not strongly arguable H had acquired confidential information about clients – Found balance of convenience did not favour applicant or H – Applicant claimed unreasonably delayed in taking action as did not know SEL was new employer – Applicant claimed failure to disclose new employer breached H’s fidelity and good faith obligations – Authority found H would suffer financially and SEL’s business would be disrupted for a short period if H prevented from dealing with existing clients - Found overall justice favoured H as applicant unlikely to obtain permanent injunctive relief – Application for injunctive relief dismissed - Business Development Manager
Result Application dismissed ; Costs reserved
Main Category Restraint of Trade
Statutes Illegal Contracts Act 1970 s8
Cases Cited Green v Transpacific Industries Group (NZ) Ltd [2011] NZEMPC 6
Number of Pages 9
PDF File Link: 2011_NZERA_Auckland_267.pdf [pdf 32 KB]