Thursday, 15 January 2015

Conduct unbecoming means no remedy

An order for reinstatement or the payment of compensation as the remedies for unfair dismissal are discretionary and not mandatory: Jeffrey v IBM Australia [2014] FWC 8166 is a case in point.

After long periods of absence because of illness IBM dismissed Ms Jeffrey, a business analyst, for the reason that on medical grounds she would not be able to fulfil the inherent requirements of her role for the foreseeable future.

The Commission found that the medical evidence upon which IBM relied did not support that conclusion and therefore found that the dismissal was not for a valid reason.

When it came to remedy the Commission found that the conduct of Ms Jeffrey at arbitration worked against any order for reinstatement or compensation being made in her favour.

The Commission was especially critical of Ms Jeffrey using the hearing to besmirch the reputation of various IBM employees without foundation and as a forum in which to raise issues, which whilst they arose from the employment relationship, were not relevant to her dismissal.

Ms Jeffery represented herself at arbitration and her underlying illness may well have affected or impaired her judgement on matters.


Even so the fact that a remedy was not ordered is a salutary lesson to all employees contesting their dismissal: be relevant, do not make gratuitous or unfounded accusations and comply with rulings and directions of the Commission.

Questions about this article or about employment and workplace matters, please contact our specialist employment and workplace relations team.

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