FEDERAL COURT OF AUSTRALIA
Construction, Forestry, Mining and Energy Union v Alfred [2011] FCAFC 13
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- Case
- [2011] FCAFC 13
- Decision Date
CaseChat Overview and Summary
The primary legal issues for the court to decide were whether the Federal Magistrates Court had correctly interpreted the requirements of section 789 of the Workplace Relations Act 1996 (Cth), particularly in relation to the meaning of the intent to coerce, and whether the evidence supported a finding that the unions were liable under Part 16 of the Act. The court also had to consider the approach to be taken by an appellate court in reviewing findings of fact based on credibility assessments made by the court at first instance.
The Federal Court of Australia reviewed the evidence and found that the Federal Magistrates Court had not erred in its assessment of the credibility of the witnesses. The court held that the findings of fact based on credibility assessments are generally not reviewable on appeal unless there is incontrovertible evidence or compelling inferences that demonstrate the trial judge's conclusions were erroneous. The appellate court found no such error in this case. The court further found that the New South Wales Branch was not outside the operation of Part 16 of the Workplace Relations Act 1996 (Cth), as required by section 785(1)(f)(ii) of the Act.
Given that the appellants failed to establish any "appellable error" on the part of the Federal Magistrates Court and the specific issues raised on appeal were limited, the appeal was dismissed. The Federal Court of Australia upheld the decision of the Federal Magistrates Court in its entirety.
ORDERS:
1. The appeal be dismissed.
Orders
Orders of the court
1. The appeal be dismissed.
Note:
Background
Background to the litigation
Evidence
Evidence Before The Court
Full text does not contain this section.
Decision
Reasons for decision
Ratio Decidendi
Legal Principle Established
Secondly, as contended by a Notice of Contention filed in the appeal, a sufficient connection to the New South Wales branch, having regard to Mr Manna’s conduct which is to be imputed to it, arises from s 785 of the WR Act, which applies Part 16 of the WR Act as follows:785 Constitutional corporations(1) This Part applies to the following conduct:…..(f)conduct carried out with intent to directly affect a person in the capacity of:…(ii) a contractor, or prospective contractor, of a constitutional corporation; The partners of Anything Concrete contracted with Conform, which itself took a contract from North East. The matters pleaded in the amended statement of claim alleged sufficient material facts which would, if proved, sustain a conclusion that Conform and North East were each constitutional corporations. The evidence sufficiently proved those facts. That was sufficient to engage the operation of s 785(1)(f)(ii) with the result that the New South Wales branch was not outside the operation of Part 16 of the WR Act. As a result, there is no separate basis to dismiss the proceedings against the New South Wales branch.Conclusion A challenge to the penalties imposed was withdrawn by the written submissions filed for the appellants. The arguments upon which the appellants rely having been rejected, the appeal should be dismissed. This is an appeal from two decisions of a Federal Magistrate, the first given on 10 July 2009 (Alfred v Construction, Forestry, Mining & Energy Union [2009] FMCA 613, 185 IR 325); the second given on 20 October 2009 (Alfred v Construction, Forestry, Mining & Energy Union (No 2) [2009] FMCA 1003). The Notice of Appeal was filed in this Court on 10 November 2009 and the Respondent filed a Notice of Contention on 18 December 2009. The opportunity has been taken to read the reasons for decision of Buchanan J. His Honour’s careful and detailed review of the evidence advanced before the Federal Magistrate removes any necessity to again do so. Concurrence is expressed with the conclusion of Buchanan J that the appeal is to be dismissed. Less reservation is experienced, however, in reaching that conclusion than that expressed by Buchanan J, primarily because of two inter-related considerations, namely:·the necessity for the Appellants to establish “appellable error” on the part of the Federal Magistrate and their failure to do so; and ·the manner in which the proceeding was conducted before the Federal Magistrate and the confined issues raised for resolution on appeal. The jurisdiction presently being exercised in this appeal is that conferred by s 24(1)(d) of the Federal Court of Australia Act 1976 (Cth), namely the jurisdiction to hear and determine appeals from judgments of the Federal Magistrates Court. That jurisdiction is in the nature of a complete re-hearing: Farrington v Deputy Commissioner of Taxation [2002] FCA 1013, 50 ATR 429 per Kenny J; Kowalski v Domestic Violence Crisis Service [2005] FCA 12 at [51] per Madgwick J. See also: Branir Pty Ltd v Owston Nominees (No 2) Pty Ltd [2001] FCA 1833, 117 FCR 424.