Rangi and Action Workforce Pty Ltd and Ors

In the matter of *Rangi v Action Workforce Pty Ltd and Ors*, heard before Judge Blake in the Fair Work Commission, the applicant brought proceedings alleging breaches of the general protections provisions of the *Fair Work Act 2009* (Cth). The dispute centred on claims of bullying, harassment, and discrimination, with the applicant asserting that the named respondents had taken or threatened to take unlawful adverse action against them. A key factual element was that the applicant's relevant employer was not named as a respondent in the proceedings.

The primary legal issues before the Commission were whether the applicant had sought relief against the appropriate respondents, whether any of the named respondents had engaged in conduct constituting unlawful adverse action or threatened such action, and whether these actions contravened the *Fair Work Act 2009* (Cth) in relation to bullying, harassment, or discrimination. The Commission was required to determine if the applicant's claims were legally sustainable given the parties involved and the nature of the alleged conduct.

Judge Blake found that the applicant had failed to establish that adverse action had been taken against them by the named respondents. Crucially, the absence of the applicant's actual employer as a party to the proceedings meant that the Commission could not find a contravention of the general protections provisions of the *Fair Work Act 2009* (Cth) in relation to the alleged bullying, harassment, or discrimination. Consequently, the application was dismissed.