FEDERAL COURT OF AUSTRALIA
Deam v Starlight Children’s Foundation Australia [2023] FCA 259
File number: VID 443 of 2022 Judgment of: MORTIMER J Date of judgment: 24 March 2023 Catchwords: INDUSTRIAL LAW – interlocutory application seeking summary dismissal of proceedings pursuant to s 31A of the Federal Court of Australia Act 1976 (Cth) and r 26.01(1)(a) of the Federal Court Rules 2011 (Cth) – whether s 734 of the Fair Work Act 2009 (Cth) precludes the applicant from making a general protections application to this Court in circumstances where the applicant’s prior Australian Human Rights Commission complaint was terminated – whether conduct is substantially the same – interlocutory application granted – proceedings dismissed
HUMAN RIGHTS – application for leave to bring proceedings pursuant to s 46PO of the Australian Human Rights Commission Act 1986 (Cth) – whether claims have reasonable prospects of success – leave refused
Legislation: Australian Human Rights Commission Act 1986 (Cth) ss 46P(2)(a)(i), 46PH(1)(c), 46PO(1), 46PO(3A)
Disability Discrimination Act 1992 (Cth) ss 4, 5(2), 6, 11, 15(2)
Fair Work Act 2009 (Cth) ss 340, 342, 351, 368(4), 539, 570, 725, 734
Federal Court of Australia Act 1976 (Cth) s 31A
Federal Court Rules 2011 (Cth) r 26.01(1)(a)
Workplace Injury Rehabilitation and Compensation Act 2013 (Vic) ss 103, 104
Cases cited: Allianz Australia Insurance Ltd v Delor Vue Apartments CTS 39788 [2021] FCAFC 121; 287 FCR 388
Budini v Sunnyfield [2019] FCA 2164
Chircop v Technical and Further Education Commission [2022] FCA 1015
Fair Work Ombudsman v Foot & Thai Massage Pty Ltd (in liquidation) (No 4) [2021] FCA 1242
Grigor-Scott v Jones [2008] FCAFC 14; 168 FCR 450
James v WorkPower Inc [2018] FCA 2083
Jones v Westpac Banking Corporation [2020] FCA 238
Knowles v Commonwealth [2022] FCA 741
Matthews v Markos [2019] FCA 1827
Owen v Serendipity (WA) Pty Ltd t/as Advanced Personnel Management [2020] FCA 1826
Pathmanathan v St John of God Healthcare Inc [2019] FCA 1460
Praljak v Commonwealth [2022] FCA 1438
Quirk v Construction, Forestry, Maritime, Mining and Energy Union [2021] FCA 1587; 398 ALR 39
Sayed v Construction, Forestry, Mining and Energy Union [2015] FCA 27; 327 ALR 460
Trotta v Northern Health [2021] FCA 668
Watts v Australian Postal Corporation [2014] FCA 370; 222 FCR 220
Webster v Lampard [1993] HCA 57; 177 CLR 598
Western Union Business Solutions (Australia) Pty Ltd v Robinson [2019] FCAFC 181; 272 FCR 547
Division: Fair Work Division Registry: Victoria National Practice Area: Employment and Industrial Relations Number of paragraphs: 115 Date of hearing: 16 February 2023 Counsel for the Applicant: Mr J McKenna Solicitor for the Applicant: Harmers Workplace Lawyers Counsel for the First Respondent: Mr S Meehan Solicitor for the First Respondent: Lander & Rogers Counsel for the Second Respondent: Ms J Moir Solicitor for the Second Respondent: DLA Piper Counsel for the Third Respondent: Mr A Denton Solicitor for the Third Respondent: Victorian Government Solicitor’s Office ORDERS
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- Case
- [2023] FCA 259
- Decision Date
CaseChat Overview and Summary
The court found that Ms Deam's claims were barred by s 734 of the Fair Work Act. The court ruled that the conduct Ms Deam sought to allege in her Disability Discrimination Act claim overlapped substantially with the conduct she had previously complained about to the Australian Human Rights Commission (AHRC). Consequently, the court concluded that Ms Deam's claims were precluded under s 734. The court also noted that Ms Deam's Disability Discrimination Act claims lacked sufficient material facts to establish the reasonableness of the adjustments she sought from Starlight. Therefore, the court dismissed the interlocutory application and the proceeding, finding that there were no reasonable prospects of success for Ms Deam's claims.
The court granted the interlocutory application seeking summary dismissal of Ms Deam's proceedings. The court found that Ms Deam's claims were precluded by s 734 of the Fair Work Act, as the conduct she sought to allege in her Disability Discrimination Act claim overlapped substantially with the conduct she had already complained about to the AHRC. Additionally, the court held that Ms Deam's claims lacked sufficient material facts to establish the reasonableness of the adjustments she sought from Starlight. Consequently, the court dismissed the proceeding and refused leave to commence proceedings under the Australian Human Rights Commission Act 1986 (Cth). There was no order as to costs.
Orders
Orders of the court
1. Leave to commence a proceeding under s 46PO of the Australian Human Rights Commission Act 1986 (Cth) be refused.
2. The interlocutory application filed by the applicant on 28 October 2022 be dismissed.
3. The proceeding be dismissed.
4. There be no order as to costs.
Note: Entry of orders is dealt with in Rule 39.32 of the Federal Court Rules 2011.
Background
Background to the litigation
Evidence
Evidence Before The Court
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Decision
Reasons for decision
Ratio Decidendi
Legal Principle Established
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