Hayes v State of Queensland

The appeal before the court concerned the claims of four appellants who were managers in a government department, who suffered psychiatric injury. The appellants alleged that they had been subjected to complaints from their employees and their union, which were investigated by their employer and subsequently rejected. The appellants further contended that there was a lack of support in the workplace after the complaints were made, which led to their psychiatric injuries. The trial judge dismissed the claims, finding that no duty of care was owed to the appellants, and that the employer did not breach its duty of care. The court of appeal was asked to consider whether the trial judge erred in concluding that no duty of care arose in the circumstances, and whether the employer breached its duty of care in respect of each appellant.

The primary legal issue before the court was whether the employer owed a duty of care to the appellants, and if so, whether the employer breached that duty of care. The court considered the principles of negligence and the established case law on the duty of care owed by employers to their employees. The court noted that the basis for the appellants' claims was an investigation by their employer, which was rejected. The court found that the employer did not owe a duty of care to the appellants in the circumstances, as the employer's investigation of the complaints was a legitimate exercise of its employment powers, and the appellants' claims were not reasonably foreseeable. The court also found that the employer did not breach any duty of care owed to the appellants, as the employer had taken reasonable steps to address the complaints and support the appellants in the workplace.

The court of appeal dismissed the appeal and found that the trial judge did not err in concluding that no duty of care arose in the circumstances. The court found that the employer's investigation of the complaints was a legitimate exercise of its employment powers, and the appellants' claims were not reasonably foreseeable. The court also found that the employer did not breach any duty of care owed to the appellants, as the employer had taken reasonable steps to address the complaints and support the appellants in the workplace. The court further found that the appellants' psychiatric injuries were not caused by the employer's breach of duty, as the facts assumed as the basis for the psychiatrist’s expert evidence were substantially different from the facts proved at trial. The court dismissed the appeal with costs.

The court made no orders beyond dismissing the appeal with costs. The appellants were not successful in their claims against the employer, and the trial judge's decision was affirmed. The court's decision provides guidance on the duty of care owed by employers to their employees in the context of workplace complaints and the circumstances in which such a duty may arise.