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Yong t/a Yong & Co Chartered Accountants v Chin
CA 359/07
Heard: 16 Jun 2008, Wellington
Judgment Date: 25 Jun 2008
Court/Authority: O'Regan, Arnold and Baragwanath JJ
Appearances: E Orlov ; CJ Eggleston
COURT OF APPEAL – Practice and procedure – Application for leave to appeal against an Employment Court decision – Employment Relations Authority found respondent constructively dismissed – Employment Court dismissed de novo challenge and increased compensation award – Applicant raised six points of law and cited six instances of breaches of natural justice and predetermination – Applicant submitted increased compensation award by Employment Court breach of natural justice – HELD – None of the points of law raised an issue suitable for adjudication – No substance to first five points based on breaches of natural justice – On sixth point, Judge should have given express notice of possibility of increased compensation – No proper basis to grant leave due to small sum – Application dismissed – Accountant
This was an unsuccessful application for leave to appeal against an Employment Court decision.
The applicant employed the respondent in his accounting practice. The respondent’s husband borrowed a sum of money from the appellant. The respondent had no knowledge of her husband’s debt to the applicant which the respondent’s husband ultimately failed to repay. A year later, after some discussion between the applicant and respondent about the debt, the applicant arrived unannounced at the respondent’s home with an associate and demanded to discuss the debt with her husband. The respondent resigned and brought a personal grievance for constructive dismissal.
The Employment Relations Authority found in the respondent’s favour and awarded lost wages, holiday pay and compensation for loss of dignity, hurt and humiliation of $5,000. The applicant challenged the Authority’s determination by way of a full hearing of the entire matter de novo. The Court dismissed the challenge, confirmed the Authority’s orders and increased the compensation from $5,000 to $8,000. (See: [2007] ERNZ 322).
The applicant raised six points of law and cited six instances of breaches of natural justice and predetermination. The sixth alleged breach of natural justice focused on the Employment Court’s increased award of compensation.
Held
(1) The Court considered that none of the six “points of law” identified in the application for leave to appeal raised an issue suitable for adjudication in this Court. (para 12)
(2) Turning to the grounds based on breach of natural justice and predetermination, the Court considered that there was no substance in points one to five. Point six was more troublesome. The Judge increased the level of compensation, even though, according to the applicant’s counsel, the respondent did not seek an increase and counsel was not put on notice that this was in contemplation. If that was so, the Court considered that the Judge should have given express notice in advance that he was contemplating increasing the compensation award so that counsel had the opportunity to make submissions on the point on the applicant’s behalf. However, given the small amount at issue ($3,000) the Court did not consider that this was a basis on which it could properly give leave. The application for leave to appeal was dismissed. (paras 15-17)
Result: Application dismissed (leave to appeal) ; Costs in favour of respondent ($1,500 plus disbursements)
Statutes considered:
ERA s103A
ERA s214
ERA s216
New Zealand Bill of Rights Act 1990 s15
Cases referred to in judgment:
Air New Zealand Ltd v Hudson [2006] ERNZ 415
Auckland Shop Employees Union v Woolworths (NZ) Ltd [1985] 2 NZLR 372 (CA)
Bryson v Three Foot Six Ltd [2005] 3 NZLR 721
NZ Employers Federation Inc v National Union of Public Employees [2001] 1 ERNZ
212 (CA)
NZ Amalgamated Engineering IUOW v Ritchies Transport Holdings Limited [1991] 2
ERNZ 267
R v Slater [1997] 1 NZLR 211
Yong (t/a Yong & Co Chartered Accountants) v Chin [2007] ERNZ 322
Pages: 2
[975113]
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Air Nelson Ltd v Neill
CC 15/08
Heard: 30 Apr 2008 - 1 may 2008 (2 days) Christchurch
Judgment Date: 28 Oct 2008
Court/Authority: Couch J
Appearances: K Thompson, D Ferrier ; R McCabe
DE NOVO CHALLENGE TO DETERMINATION OF EMPLOYMENT RELATIONS AUTHORITY – Disadvantage – Suspension of medical certificate – s27C(2) Civil Aviation Act requires airline operators to inform Civil Aviation Authority (“CAA”) as soon as practicable of changes to medical condition of pilots that may affect flight safety – Plaintiff’s Manager of Flight Operations (“G”) informed CAA of concerns about defendant’s medical condition – CAA suspended defendant’s medical certificate – Defendant alleged unjustifiably disadvantaged by plaintiff’s actions – Plaintiff submitted that statutory obligations not subject to obligations as employer, that s27C(2) imposes low threshold which had been met, that suspension not an action taken by plaintiff, and that defendant had not suffered disadvantage – Defendant submitted that plaintiff obliged to properly investigate concerns and verify facts before making report, that plaintiff had insufficient data to make report, and that plaintiff had not made report as soon as practicable – Further, that plaintiff’s use of information given by defendant off the record was a breach of good faith – HELD – Fair and reasonable employer will comply with statutory obligations – Low threshold to trigger obligation – Investigation and sound data not required – Sufficient information to require report – G obliged to convey information given off the record – G failed to report as soon as practicable – Failure an unjustifiable action – Disadvantage not result of unjustifiable action – Personal grievance not sustained – Challenge granted – Pilot
This was a successful de novo challenge to a determination of the Employment Relations Authority which held that the defendant was disadvantaged in his employment but that the disadvantage was not the result of the unjustifiable actions of the plaintiff.
The plaintiff employed the defendant as a commercial pilot. The Civil Aviation Act 1990 (“CA Act”) required the defendant to maintain a medical certificate consistent with his licence. The plaintiff was categorised as an “operator” under the CA Act. Section 27C(2) of the CA Act required an operator to advise the licence holder and the Director of Civil Aviation as soon as practicable if the operator was aware of, or had reasonable grounds to suspect, any change in the medical condition of a licence holder that may interfere with the safe exercise of the privileges to which the licence holder’s medical certificate related.
From July to October 2005 the defendant undertook intensive training for certification on a new type of aircraft. The defendant found the training demanding and suffered from fatigue. On 12 November 2005, the defendant had an argument with café staff at Hawke’s Bay airport about the meal he was served. The café manager complained to the plaintiff about the defendant’s behaviour. On 30 November the defendant met with the plaintiff’s Line Operations Manager (“K”) to discuss the café incident and an allegation that the defendant had inappropriately taken sick leave. Following that meeting the defendant had an altercation with the employee who had made the allegation concerning sick leave. On 1 December 2005, another pilot (“P”) advised K of his concerns about the defendant.
K discussed this information with the plaintiff’s Manager of Flight Operations (“G”), who had responsibility for maintaining safety and who was accountable to the Director of Civil Aviation. On 5 December 2005, G and the defendant had an “off the record” discussion. The defendant told G that he had been affected by lack of sleep, that he was receiving counselling for stress, and that his blood pressure was unusually high. G suggested that the defendant take two weeks off work. The defendant agreed and said he would see the medical examiner. Between 6 December 2005 and 14 December 2005, G spoke with three different doctors regarding the defendant’s medical condition. On 14 December 2005, G telephoned the senior medical officer (“Dr P”) for the Civil Aviation Authority (“CAA”) to discuss his concerns about the defendant’s medical condition. Later that day, Dr P suspended the defendant’s medical certificate. Following an investigation, the defendant was able to obtain a new medical certificate and returned to work.
The defendant brought a personal grievance alleging that he had been disadvantaged by the unjustifiable actions of the plaintiff. The Authority found the personal grievance action was made out. The plaintiff challenged that determination.
The plaintiff submitted that s 27C(2) of the CA Act imposed a statutory obligation on G which was not subject to any obligations that the plaintiff had as an employer. In the plaintiff’s submission, s27C(2) imposed a low threshold and that threshold had been reached. The plaintiff argued that the suspension was an action taken by the CAA, not the plaintiff. Finally, the plaintiff submitted that the defendant’s employment had not been affected to his disadvantage.
The defendant submitted that G was obliged under s 27C(2) of the CA Act to investigate his concerns regarding the defendant’s medical condition and to verify facts before making a report to the CAA. The defendant alleged that G had not conducted a proper investigation and that the information was insufficient to trigger the obligation to report. Further, that G had a strong duty to report promptly and that he had not notified his concerns as soon as practicable. Finally, the defendant argued that the use of information given “off the record” was a breach of good faith.
Held
(1) It is axiomatic that a fair and reasonable employer will comply with statutes binding on it. It follows that, where the action alleged to be unjustifiable is taken pursuant to a statute, whether it is justifiable will be inextricably linked to whether there was compliance with that statute. (para 72)
(2) The words used in s27C(2) create a low threshold. The operator need not know or be certain. All that is required is “reasonable grounds to suspect”. What is suspected need not be any particular condition or disability. It is sufficient if the suspicion relates to “any change in the medical condition” of the licence holder. The operator need not establish that the suspected change will affect safety but only that it “may” do so. A low threshold is consistent with the overriding emphasis of the CA Act on safety. (paras 74-75)
(3) In terms of the degree of certainty required to meet the threshold, counsel for the defendant submitted that any report must be based on “sound data” and that it must relate to “a real, credible and significant change to the pilot’s medical condition”. That overstated the requirement of the statute. The primary meaning of the word “suspect” provided in the Concise Oxford English Dictionary, 11th ed (2006), is “believe (something) to be probable or possible”. That clearly allows for a substantial degree of uncertainty. By its very nature, suspicion is subjective and may occur as a result of many different processes. It will often be formed without conscious analysis. It certainly need not be the result of inquiry or investigation. (para 76)
(4) The proper body to conduct any investigation of suspected changes in medical condition is the Director, through the medical officers retained by the CAA. (para 79)
(5) The requirement that any report under s27C(2) be made “as soon as practicable” reflects a legislative intention that the Director should know without delay of the possibility of change in a pilot’s medical condition. If it was intended that an operator should investigate any concerns and verify the accuracy of them before reporting to the Director, that intention would be seriously compromised. The obligation to report arises as soon as the threshold under s27C(2) is reached. (paras 80, 84)
(6) Overall, the Court found that the information was clearly sufficient to constitute reasonable grounds to suspect that there had been a change in the defendant’s medical condition. The Court also accepted the evidence of G that he actually had such a suspicion. (para 82)
(7) G gave evidence that stress and fatigue can cause a pilot to lose concentration and thereby create a safety hazard. In answer to questions in cross examination, the defendant effectively agreed with that view. The Court accepted that evidence which satisfied the third component of the threshold under s27C(2) that the suspected change in the medical condition may affect flight safety. (para 83)
(8) To find that an obligation to investigate suspicions before making a report arose out of the employment relationship would require the operator to act in a manner inconsistent with s27C(2) of the CA Act. That is not what a fair and reasonable employer would do. (para 91)
(9) The suspension of the defendant’s medical certificate was a likely and foreseeable consequence of G’s report to Dr P. In that sense, it was the result of his actions. (para 94)
(10) In order to comply with s27C(2), G was obliged to convey to Dr P the information the defendant had provided to him, regardless of the circumstances in which it was provided. The Court found that, in telling Dr P of his concerns about the defendant, G did what a fair and reasonable employer would do. (para 95)
(11) The threshold under s27C(2) was probably reached on 5 December 2005 and it was certainly reached by 6 December 2005. That being so, G’s obligation to inform the CAA of his concerns arose no later than 6 December 2005. The only respects in which the plaintiff’s actions were not what a fair and reasonable employer would have done were that G failed to advise either the Director or the defendant “as soon as practicable” of his concerns about the defendant’s medical condition. To that extent, the Court found that the actions of the plaintiff were unjustifiable. (paras 85, 99)
(12) All of the disadvantage to the defendant’s employment which was established by evidence arose out of the suspension of the defendant’s medical certificate and his subsequent disqualification from holding a medical certificate. The Court found that G’s delay in discharging the obligations of the plaintiff under s27C(2) neither caused nor contributed to that disadvantage. It followed that the defendant’s personal grievance was not sustained. (para 100)
Result: Challenge granted ; No order for costs
Statutes considered:
Civil Aviation Act 1990 s27B
Civil Aviation Act 1990 s27C
Civil Aviation Act 1990 s27C(2)
Civil Aviation Act 1990 s27I
Civil Aviation Act 1990 s27O
Civil Aviation Act 1990 Part 2A
ERA s4
ERA s103A
Words and phrases: suspect
Cases referred to in judgment:
Dulcie Holdings Ltd v New Zealand Customs Service [1997] DCR 1077 (DC)
Oceania Aviation Ltd v The Director of Civil Aviation HC, Wellington, CP162/98, 9
August 2000
Victoria University of Wellington v Haddon [1996] 1 ERNZ 139 (CA)
Pages: 4
[975530]
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HP Industries (NZ) Ltd v Davison
AC 44/08
Heard: 11 Sep 2008, Auckland
Judgment Date: 7 Nov 2008
Court/Authority: Shaw J
Appearances: R Towner ; G Muller
DE NOVO CHALLENGE TO DETERMINATION OF EMPLOYMENT RELATIONS AUTHORITY – Redundancy – Disadvantage – Defendant accepted redundancy justified substantively but alleged procedure caused unjustifiable disadvantage – Defendant called to meeting without notice and advised of restructuring but not provided information on alternative options – Later offered alternative position but not advised pay rate – Plaintiff ended consultation process when defendant tried to discuss issues and alternatives – Plaintiff submitted that process was fair, that any limitation on consultation was due to defendant’s unwillingness to participate, that it complied with obligations in employment agreement, and that it acted as a fair and reasonable employer would have done – HELD – Plaintiff breached obligation to provide defendant with proper information – Consultation process hasty and abruptly ended – Plaintiff did not act as a fair and reasonable employer – Unjustified disadvantage – Challenge dismissed – Single process engineer
This was an unsuccessful de novo challenge to a determination of the Employment Relations Authority which held that the defendant was unjustifiably affected to his disadvantage by the plaintiff’s actions.
The plaintiff had employed the defendant since 1987. In 2006, the plaintiff decided to disestablish five positions including the defendant’s. The plaintiff’s Operations Manager (“R”) disclosed the managers’ review to union representatives but did not discuss the review with the defendant.
On 16 November 2006, R called the defendant to a meeting. The defendant was not advised of the purpose of the meeting. The plaintiff’s legal representative had emailed R an explanatory letter to be given to affected employees but the defendant arrived early, and R had not printed the letter. The defendant gave evidence that R told him he was being made redundant. R said he told the defendant that the plaintiff was considering restructuring and that the defendant’s position may be affected. The defendant was told to take time off and to take his tools home. At the end of the meeting R printed and gave the explanatory letter to the defendant. The letter directed the defendant not to attend work and not to contact other employees, suppliers or customers.
The next day the defendant requested details of his employment agreement and redundancy package. R provided the estimated redundancy calculations on 23 November 2006 and the employment agreement on 27 November 2006. The defendant and his lawyer met with R on 28 November 2006. When the defendant asked about alternative positions, R asked the defendant for ideas. The following day R advised the defendant by email that the only available position was as a shift technician at “the current going rate”, which was not specified. R said that the meetings had been delayed and he would like to reach a conclusion and suggested the parties meet later that day. The defendant read the email at the end of the day and replied he would respond once he had heard from his lawyer. R responded the following morning stating that the company had gone out of its way to allow as much time as possible for consultation and would not delay the process indefinitely.
The parties met again on 1 December 2006. Prior to the meeting, at R’s request, the defendant’s lawyer had emailed R outlining concerns, issues and alternatives. R was unable to open the attachment. At the start of the meeting, R requested an answer to the offer of the shift technician position. The defendant’s lawyer then gave R a hard copy of the attachment. R was annoyed and ended the meeting by printing out a preprepared letter which reiterated the job offer and said if the offer was not accepted the defendant’s employment would be terminated for redundancy. No time limit was
given for acceptance. On 4 December 2006, R emailed the defendant a letter to terminate his employment.
During the consultation process the plaintiff was aware that the defendant’s wife was pregnant with twins and that one of the defendant’s children was in hospital. The defendant brought a personal grievance for unjustified dismissal. The Authority found that while his dismissal resulted from genuine restructuring, the defendant’s particular employment was not genuinely redundant. It determined that the dismissal was procedurally unjustified and awarded $5,000 compensation. The plaintiff challenged that determination. In the challenge, the defendant accepted that his redundancy was substantively justified and the only claim before the Court was that he was unjustifiably disadvantaged in his employment by the process.
The plaintiff submitted that the dismissal was carried out fairly and any limitation on consultation was as a result of the defendant’s unwillingness to participate, that the plaintiff met its obligations in the employment agreement, and its actions were what a fair and reasonable employer would have done in the circumstances.
Held
(1) The Court found that there were significant and unjustified process failures by the company. First was the inconsistent treatment of the defendant as an employee covered by an individual employment agreement compared with employees who had union representation. (para 45)
(2) The letter given to the defendant at the end of the 16 November meeting expressed what R intended to say to the defendant but the Court had strong doubts that he followed the format of the letter when speaking to him. The defendant came away from the meeting with a very different understanding from that which R intended to convey. This was partially because he did not have the chance to read the letter at the meeting and clarify matters with R before leaving. (para 47)
(3) The meeting on 16 November was not consultation in the proper sense. The defendant was notified of a restructure that was necessarily having to proceed and was told that he needed to consider his options but was not provided with sufficient information at that stage in a form that would enable him to do this. For example he was given no indication of what options the company may have had available for him. (para 48)
(4) The direction to the defendant not to attend work and cease contact with other employees was harsh. Although it appears it was intended to give the defendant time to consider his options, in the absence of information about those options and, because he had been told to take his tools home, it was understandable that he believed the decision had already been made. (para 49)
(5) R was wrong to believe that the real consultation would only begin once the defendant put forward some proposals. Section 4(1A) recognises that the provision of information relevant to the continuation of an employee’s employment is the responsibility of the employer. The obligation is on the employer to provide the employee with information about possible alternatives to redundancy or options for redeployment. Without that information R’s request for the defendant to initiate the discussion on options was unreasonable. (paras 50-51)
(6) Having begun what R saw as consultation by asking the defendant for his comments on the issues, R then summarily terminated it by abruptly ending the meeting on 1 December without engaging with the matters raised in defendant’s lawyer’s letter which meant that even on his terms there was no consultation at all. (para 52)
(7) The company’s letter sent to the defendant after that meeting demonstrated the extent of the unfairness of the process towards the defendant. The letter said that the plaintiff had given “comprehensive consideration” to their restructuring proposal and its consequences since first meeting with the defendant. There was no evidence that the results of this comprehensive consideration had been conveyed to the defendant. Next, the letter showed that the entire burden of coming up with options lay with the defendant. The defendant’s reaction to the offer of shift technician was to seek his lawyer’s advice. The letter showed that the plaintiff regarded this as a refusal to make a decision without the lawyer’s input. Given that the offer had not been accompanied by any pay rates or other information the company’s negative reaction to the defendant’s desire to seek legal advice was unfair. Finally, having asked for the defendant to provide comments and issues to him R then expressed frustration with the fact that those concerns and issues had been raised by the defendant’s lawyer. (para 53)
(8) R’s complaints about the delays were not justified. The longest delay was caused by him getting very relevant information to the defendant. (para 55)
(9) On a personal level, R was aware that one of the defendant’s children was in hospital for a time during this process and that his wife was expecting twins. Given that he was facing the termination of his employment of 20 years the Court found that the plaintiff acted with undue haste which caused him anxiety and stress and, the Court inferred, a good deal of frustration. (para 56)
(10) The plaintiff acted in a manner towards the defendant which unjustifiably affected him to his disadvantage. (para 57)
Result: Challenge dismissed ; Compensation for humiliation etc ($9,000) ; Costs reserved
Statutes considered:
ERA s4
ERA s4(1A)
ERA s4(1A)(c)
ERA s123(1)(c)
Cases referred to in judgment:
Simpsons Farms Ltd v Aberhart [2006] ERNZ 825
Pages: 4
[975545]
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Snowdon v Radio New Zealand Ltd
WC 19A/08
Heard: 12 Nov 2008, Wellington
Judgment Date: 11 Dec 2008
Court/Authority: Travis J
Appearances: R A Moodie ; M F Quigg. J Bates
PRACTICE AND PROCEDURE – Reasons for granting strike-out application – Plaintiff applied for compliance orders with earlier disclosure judgments and notice requiring disclosure – Plaintiff alleged defendant concealed financial arrangements and misled plaintiff and Court before and during disclosure – Earlier judgments and orders therefore vitiated – Defendant submitted Court lacked jurisdiction and that res judicata applied – Defendant submitted plaintiff’s application causing delay and prejudice – HELD – Plaintiff’s disclosure notice already set aside by Court order and Court previously found defendant had complied with disclosure obligations – Res judicata applied – Proper course of action to apply for further and better discovery in light of new information – Plaintiff should have sought to have orders set aside for fraud – Wrong proceedings filed – Causes of action untenable – Proceedings struck out – Application granted This judgment recorded the
This judgment recorded the reasons for a successful application by the defendant for an order striking out the plaintiff’s statement of claim.
The plaintiff applied for orders that the defendant comply with (a) previous judgments of the Employment Court regarding disclosure; and (b) the Employment Court Regulations 2000 and/or the notice requiring disclosure. The plaintiff relied on r52 of the Employment Court Regulations 2000 which gave the Court the power to grant compliance orders in relation to the disclosure of documents. The statement of claim asserted that before and during the substantive proceedings the defendant had attempted to conceal certain financial issues and that the defendant intentionally misled the plaintiff and the Court before and during the disclosure process. The plaintiff therefore argued that previous orders and judgments were vitiated. Finally, the plaintiff argued that new information had come to light which entitled the plaintiff to further and better discovery.
The defendant applied to have the statement of claim struck out. The defendant made four submissions. First, that the Court did not have the power to grant the orders that the plaintiff sought under r52 of the Employment Court Regulations 2000 and therefore the statement of claim did not disclose a reasonable cause of action.
Second, in the alternative, that the matters were subject to the doctrine of res judicata because the Employment Court had previously upheld the defendant’s notice of objection to the plaintiff’s notice requiring disclosure (see: [2005] ERNZ 905) and the Court of Appeal had refused leave to appeal that judgment (see: CA28/06, 23 June 2006). Third, that earlier judgments had determined that the Court’s previous orders for disclosure had been fulfilled which meant that res judicata applied and the plaintiff’s application was an abuse of process. Finally, that the current proceeding was causing further delay and prejudice to the defendant.
Held
(1) Regulation 52 is used to deal with non-compliance with disclosure in the course of a substantive proceeding. The Court was not aware of it having ever been used as a basis for separate compliance proceedings, as in the present case. Further, it only deals with situations where there has been non-compliance with either a notice requiring disclosure or a Court order made under the regulations. As the defendant’s counsel demonstrated, the plaintiff’s notice had been set aside by an order of the Court, further disclosure was ordered by the Court and there was a subsequent judgment finding that the defendant had complied with its disclosure obligations. (para 17)
(2) If the allegation that new information had come to light was correct, and assuming for the present purposes of the strike out application that it was so, then the plaintiff’s proper course of action was to apply for further and better discovery on the basis of this new information. Instead the plaintiff was seeking compliance with orders already made and with a disclosure notice that the Court had already set aside. (para 23)
(3) As counsel for the defendant fulsomely acknowledged, and the Court entirely agreed, fraud does unravel everything. However, the plaintiff’s difficulty was that the present proceedings sought compliance with the existing orders of the Court and did not seek to have them set aside on the basis of fraud. If, as the Court must assume for the purposes of the strike out application only, the plaintiff was successful in proving the serious allegations she made in her statement of claim, it could have the effect of setting aside the orders which were the very orders that the plaintiff sought to have the defendant comply with in the present proceedings. When set out in this manner it was obvious that the plaintiff had adopted the wrong proceedings in order to achieve the ends she sought. (para 27)
(4) In the absence of a proper proceeding seeking orders setting aside the Court’s judgment which affirmed that the defendant had complied with the Court’s earlier disclosure orders, those findings of the Court must stand and the defendant was entitled to rely upon them under the doctrine of res judicata. (para 28)
(5) On the assumption that the allegations contained in the statement of claim would be able to be proven at trial, the causes of action were so clearly untenable that they could not possibly succeed. This was a case in which the strike out jurisdiction should be used to avoid further delays and abuse of the processes of the Court. For all these reasons the Court struck out the plaintiff’s present proceedings. (para 29)
Result: Application granted (strike out) ; Costs in favour of defendant
Statutes considered:
Employment Court Regulations 2000 r6
Employment Court Regulations r52
ERA s139
High Court Rules R186
Cases referred to in judgment:
Clark v NCR (NZ) Corporation [2006] ERNZ 401
Edwards v Wellington Regional Council [1999] 1 ERNZ 472 (CA)
Hunter v Chief Constable of West Midlands Police [1982] AC 529; [1981] 3 All ER
727 (HL)
Lazarus Estates Ltd v Beasley [1956] 1 All ER 341
Marshall Futures Ltd (In Liq) v Marshall [1992] 1 NZLR 316; (1991) 3 PRNZ 200
(HC)
New Brunswick Railways Co v British and French Trust Corporation Ltd [1939] AC
1 (HL)
NZ (with exceptions) Shipwrights Union v NZ Amalgamated Engineering IUOW
(1989) ERNZ Sel Cas 516; [1989] 3 NZILR 284
Ongley v Brdjanovic [1975] 2 NZLR 242
Snowdon v Radio New Zealand Ltd [2005] ERNZ 905
Snowdon v Radio New Zealand Ltd WC 4/06, 27 March 2006
Snowdon v Radio New Zealand Ltd CA28/06, 23 June 2006
Snowdon v Radio New Zealand Ltd WC 4A/06, 7 December 2006
Snowdon v Radio New Zealand Ltd WC 19/08, 12 November 2008
Pages: 3
[975663]
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