FEDERAL CIRCUIT AND FAMILY COURT OF AUSTRALIA
(DIVISION 2)
Evans v Oxford Shop Pty Ltd (No 2) [2023] FedCFamC2G 663
File number: PEG 243 of 2020 Judgment of: JUDGE LUCEV Date of judgment: 27 July 2023 Catchwords: INDUSTRIAL LAW – when alleged requirement for consultation first raised by applicant – whether direction given was or was required to be a JobKeeper enabling direction – JobKeeper location change enabling direction –whether written notice given of intention to give a JobKeeper location change enabling direction – if written notice was given whether it was given three days before any JobKeeper location change enabling direction was given – whether if one or both of the requirements concerning the giving or timing of notice have not been met – whether there is a JobKeeper location change enabling direction
PRACTICE AND PROCEDURE – whether to re-open evidentiary hearing – whether proposed evidence relevant or of probative value – whether explanation for failure to call evidence – whether procedurally fair to re-open evidentiary hearing – whether prejudice to respondent
WORDS AND PHRASES – “period” – “during a period” – “writing” – “consultation”
Legislation: Acts Interpretation Act 1901 (Cth) s 2B
Fair Work Act 2009 (Cth) Part 6-4C, ss 548, 570, 789GB, 789GC, 789GDC, 789GE, 789GF, 789GK, 789GM, 789GN
Federal Circuit Court Rules 2001 (Cth) r 45.13
Matrimonial Causes Act 1875 (Qld) s 7
Cases cited: Ample Source International Limited (BVICN 1575638) v Bonython Metals Group Pty Limited ACN 141 257 294 & Ors (No. 6) [2011] FCA 1484; (2011) 285 ALR 488
Australian Fisheries Management Authority v PW Adams Pty Ltd (1995) 61 FCR 314; (1995) 22 AAR 261; (1995) 134 ALR 51; (1995) 39 ALD 481
Australian Securities and Investments Commission v Rich [2006] NSWSC 826; (2006) 235 ALR 587
Autodesk Inc v Dyson (No. 2) (1993) 176 CLR 300; (1993) 67 ALJR 270; (1993) 111 ALR 385; (1993) 25 IPR 33
Bagus v Minister for Immigration, Local Government and Ethnic Affairs (1994) 50 FCR 396; (1994) 33 ALD 601
Brown v Walters [1931] HCA 45; (1931) 46 CLR 290; (1931) 38 ALR 103; (1931) 5 ALJ 278
Cassidy & Partners Pty Ltd v Scone Shire Council (1995) 7 BPR 14,331
Construction, Forestry, Mining and Energy Union v BHP Coal Pty Ltd [2016] FCA 1009; (2016) 262 IR 176
Cunliffe v Goodman [1950] 2 KB 237; [1950] 1 All ER 720; (1950) Sol Jo 179; (1950) 155 EG 202; (1950) 66 TLR 109
Eugene Cho Pty Ltd v Minister for Immigration, Citizenship, Migrant Services and Multicultural Affairs [2021] FCCA 2020; (2021) 361 FLR 340
Evans v Oxford Shop Pty Ltd [2020] FCCA 2730
Evans v Oxford Shop Pty Ltd [2022] FedCFamC2G 438
Gardiner v Motor Vehicle Insurance Trust [1955] HCA 57; (1955) 95 CLR 120; (1955) 29 ALJ 689
Han Jian v NHP Electrical Product Pty Ltd [2004] AIRC 1227
Leeder v The Mayor, Etc, of the Town…
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- Case
- [2023] FedCFamC2G 663
- Decision Date
CaseChat Overview and Summary
The Court considered the evidence and submissions from both parties, focusing on the interpretation of the Employment Contract and the requirements of the FW Act. Ms Evans argued that the direction to work at the DFO Perth Airport Store was unreasonable due to her caring responsibilities for her mother-in-law. However, the Court found that the June 2022 Orders did not invite the parties to file further evidence but to file further written submissions limited to the application of s 789GM of the FW Act. The Court noted that the threshold for reopening a case and allowing further evidence is lower before judgment than after, and the primary consideration is the embarrassment or prejudice to the other side.
The Court concluded that the direction to work at the DFO Perth Airport Store was a lawful and reasonable direction under the Employment Contract, as it was consistent with the term "As Directed." The Court also found that the direction satisfied the requirements of a JobKeeper enabling direction in s 789GM of the FW Act, as the requisite written notice was provided to Ms Evans and the consultation requirements were met. Furthermore, the Court held that the purpose of JobKeeper was to provide additional flexibilities for employers, not to restrict existing flexibilities.
In light of the findings, the Court denied the application for further evidence and found that the direction to work at the DFO Perth Airport Store was a valid direction under the Employment Contract and the FW Act. The Court's decision underscores the importance of interpreting employment contracts and legislative provisions in the context of the specific circumstances of each case.
Orders
Orders of the court
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Background
Background to the litigation
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Evidence
Evidence Before The Court
Decision
Reasons for decision
Ratio Decidendi
Legal Principle Established
Oxford Shop’s submissions were as follows:(a)JobKeeper enabling directions were never intended to prevent employers exercising existing rights to give lawful and reasonable directions consistent with an employee’s contract of employment. Further, a JobKeeper enabling direction was not required as Ms Evans did not have a “normal place of work”, as it was referred to under the since repealed s 789GF of the FW Act as she was not working at the time she was directed to the DFO Perth Airport Store. This is also consistent with Ms Evans’ Employment Contract which did not prescribe a normal place of work, rather her “Primary Location” of employment was “As Directed”;(b)in the alternative, that although it was not described as a JobKeeper enabling direction, the direction to work at the DFO Perth Airport Store would satisfy the requirements of a JobKeeper enabling direction in s 789GM of the FW Act, as the requisite written notice was provided to Ms Evans and the consultation requirements were met;(c)that the purpose of JobKeeper was intended to provide additional flexibilities for employers to keep employees employed, not to restrict existing flexibilities;(d)nothing in the FW Act suggests that JobKeeper enabling directions in relation to work location were intended to override lawful and reasonable directions authorised by the contract of employment;(e)section 789GF(1)(a) of the FW Act authorises an employer to direct an employee to change their work location subject to the requirements of (b) to (f) of that subsection being satisfied even if a “designated employment provision” would not allow it;(f)section 789GF of the FW Act does not operate to prevent an employer otherwise directing their employees to change the location of work consistent with their contract of employment, provided that the employer is not relying upon s 789GF of the FW Act to authorise the direction;(g)section 789GF of the FW Act set out the requirements for an employee who qualified for the JobKeeper scheme (in relation to a particular employee) to be able to direct that employee during a period to perform duties at a place that was different from that employee’s normal place of work; (h)Ms Evans’ evidence was that on 15 April 2020 the Wesley Quarter Store, where she had previously been directed to work, closed permanently due to a decline in trade as a result of COVID-19 restrictions and after its closure Oxford Shop did not retrench any employees, including Ms Evans, who remained employed with Oxford Shop and application was subsequently made for JobKeeper payments;(i)as such, that Ms Evans was not working at the time that she was directed to work at the DFO Perth Airport Store, and therefore she did not have a “normal place of work” and as such, no JobKeeper enabling direction was required;(j)no “normal place of work” is prescribed in Ms Evans’ Employment Contract with “Primary Location” being “As Directed”;(k)it had consulted Ms Evans, consistent with s 789GM(1)(c) of the FW Act, by way of SMS to her on 8 July 2020 by Mr Maddox and that the text messages between Mr Maddox and Ms Evans, and the emails between Mr Togno and Ms Evans, met the requirements under s 789GM(1)(c) of the FW Act in relation to consultation;(l)during cross examination at hearing Ms Evans had conceded that it was a direction to work at the DFO Perth Airport Store;(m)the written notice, being the text messages exchanged between Ms Evans and Mr Maddox, occurred five days prior to the written direction being provided, thereby complying with s 789GM(b)(i) of the FW Act and that the direction was in the form of the email dated 13 July 2020, stating “Please see below your contract from 2015 which shows your Primary location to be “As directed” all staff in WA are now required to be employees at our DFO store”. Daniel will have you on the roster from this week”;(n)due to the closure of other store locations in Western Australia, a direction for Ms Evans to work at the DFO Perth Airport Store, Oxford Shop’s only remaining WA store, was necessary in order for her to have continued employment;(o)the JobKeeper legislation did not act to prevent Oxford Shop giving Ms Evans a lawful and reasonable direction to attend for work;(p)that in relation to Evans (No 1):(i)as to [82(a)], written notice was provided to Ms Evans;(ii)as to [82(b)], five days written notice were provided to Ms Evans;(iii)as to [82(c)], that although it was not described as a JobKeeper enabling direction, the direction to work at the DFO Perth Airport Store would satisfy both the requirements of a JobKeeper enabling direction in s 789GM(1)(a) and (b)(i) of the FW Act; and(iv)as to [82(d)], that there was a valid direction for the purposes of the Employment Contract as Ms Evans’ “Primary Location” of employment is “As Directed” and the direction was held in Evans (No 1) to be lawful and reasonable; and(q)Ms Evans now appears to seek to provide evidence in relation to carer’s responsibilities and in relation thereto Oxford Shop:(i)objects to such evidence now being tendered; and(ii)submits that:(A)the evidence was not given at hearing: Evans (No 1) at [80];(B)carer’s responsibilities was never raised by Ms Evans as a reason not to work at the DFO Perth Airport Store;(C)as the matter has been determined, no regard should be had to Ms Evans’ new material; and (D)the June 2022 Orders only allowed for the filing of submissions not evidence.CONSIDERATIONLegislative provisions