Category: Labour Law

CAN I BRING MY ATTORNEY WITH TO AN INTERNAL DISCIPLINARY HEARING?

According to item 4 of the Code of Good Practice (“the code”), the definition of dismissal contained in Schedule 8 of the Labour Relations Act (“LRA”) states that, when an employee is charged with misconduct, “[t]he employee should be allowed… the assistance of a trade union representative or fellow employee”. However, what happens in the instance when you do not belong to a trade union, or alternatively, a fellow employee is unwilling to assist you?

An employee does not automatically have the right to a legal representative during a disciplinary hearing held at their workplace. However, the employee may bring a formal application prior to the hearing for the presiding officer to consider allowing an external representative to assist the employee at the disciplinary hearing.  When exercising such discretion, the presiding officer should take certain factors into account, and the decision in respect of such an application is final, although the employee can still refer a dispute to the CCMA or Bargaining Council for procedural unfairness.

These are the factors to be considered:

  • The company policy;
  • The serious nature and complexity of the matter (whether it is in respect of a point of law or the merits of the matter);
  • The potential severity of the consequences of an adverse finding;
  • The potential adverse effects on both parties, if legal representation is allowed in comparison to when it is not allowed.

However, what happens when the employer blatantly refuses the application, or the company policy prohibits the use of an external legal representative during a disciplinary hearing?

In the case of MEC: Department of Finance, Economic Affairs and Tourism: Northern Province vs Schoon Godwilly Mahumani, the Supreme Court of Appeal held that even when the employer’s disciplinary policy prohibits the use of an external representative, it may be allowed in certain circumstances. The court held that the employer’s policy must be viewed as a guideline, which may be departed from under appropriate circumstances. Therefore, ultimately leaving it to the presiding officers to decide.

In Molope v Mbha and Others, the Labour Court held that even though the dismissal of an employee who was charged with the unauthorised use of funds was substantively fair, the dismissal was procedurally unfair. The employee, prior to the disciplinary hearing, requested a postponement of the said hearing, in order to obtain an external representative as a fellow employee who had agreed to assist the accused employee decided to no longer assist shorty before the hearing.  The employer however refused the postponement.

The decision of the presiding officer on such application is final. However, should the employee wish to appeal against this decision, the employee still has the option of referring the dispute to the CCMA or Bargaining Council for procedural unfairness upon the completion of the disciplinary process.

Therefore, should employers not disclose the option to use an external representative, via their policies or the notice of disciplinary hearing, it does not preclude employees from seeking the assistance of such representative. In the light of the above, it must still be kept in mind that it is not illegal for an employer to have a policy prohibiting assistance from external representatives. However, should the employee wish to make use of external legal representation, the request must be duly considered based on the aforementioned factors, as opposed to a mere outright denial of the request.

This article is a general information sheet and should not be used or relied on as legal or other professional advice. No liability can be accepted for any errors or omissions nor for any loss or damage arising from reliance upon any information herein. Always contact your legal adviser for specific and detailed advice. Errors and omissions excepted (E&OE)

References:

MEC: Department of Finance, Economic Affairs and Tourism: Northern Province vs Schoon Godwilly Mahumani 2005 2 All SA 479 (SCA)

Ivan Israelstam “Disciplinary Hearings: When should external counsel be permitted?” – http://www.labourguide.co.za/most-recent/1295-lawyers-may-be-allowed-at-disciplinary-hearings

Molope v Mbha and Others (JR1950/02) [2005] ZALC 48 (1 February 2005)

The Right to representation – https://www.labourguide.co.za/discipline-dismissal/673-the-right-to-representation

HOW DOES THE PROCESS TO CLAIM UNDER COIDA WORK?

When dealing work related accidents, there still seems to be a lot of uncertainty relating to the correct reporting and recording procedures of work related injuries. The Compensation for Occupational Injuries and Diseases Act, Act 130 of 1993 (“COIDA”) is the governing Act in South Africa that deals with occupational injuries and diseases.

The aim of COIDA is to provide for compensation in the case of disablement caused by occupational injuries or diseases, sustained or contracted by employees in the course of their employment, or death resulting from such injuries or disease; and to provide for matters connected therewith. COIDA prevents employees covered by the Act from suing their employers for damages in terms of common law.

Any employer with one or more employees must register with the Compensation Fund and pay annual assessment fees. Claims for employees employed in the mining and building industries must be referred to the relevant mutual associations. Claims by employees working for individually liable employers such as the state, parliament, the provincial authorities and local authorities – which have been exempted from making payments to the compensation fund – must be referred to the employer. The following steps, as set out below, should be followed when reporting to and claiming from the Compensation Fund in terms of COIDA:

  1. The accident must be reported when an employee injures himself or herself, out of and in the course of employment resulting in a personal injury for which medical treatment is required.

Written or verbal notice of an injury at work is to be given to the employer before the completion of the shift or end of the workday. Good practice on the side of the employer will be to make a list of all witnesses of the accident for the further investigation of the incident. An official form needs to be completed – known as the “W.Cl 2 Form – Notice of Accident and Claim for Compensation”. This form should be completed whenever an employee has an accident out of or in the course of employment leading to personal injury, medical treatment or death. It is the employer’s duty to submit the W.Cl 2 form, within a period of 7 days after the accident to the Compensation Commissioner.

After the completion of the form, the employer must send the form with a certified copy of the employees identity document and the first medical report (“W.Cl 4 form”) to Compensation Commissioner. A medical practitioner should complete the W.Cl 4 form, stating the seriousness of the injury, as well as the time period the employee is likely to be absent from work. Once completed, the medical practitioner sends it to the employer who forwards same to the Commissioner. Employees are not responsible for the payment of medical costs in this regard, however, if an employee requests a second medical practitioner’s opinion, he/she will be liable for the payment of medical costs.

  1. After the Compensation Commissioner receives the abovementioned documents, he/she will then register the claim and forward a postcard (“W.Cl.55”) to the employer. A claim number is provided on the postcard and this number should be used for all paperwork relating to a claim. When the first doctor’s report has been submitted with the accident report, the Compensation Commissioner will consider the claim and make a decision.

After the Compensation Commissioner has considered the claim a postcard (“W.Cl.56”) will be sent to the employer. The W.Cl.56 postcard, will only be used by the Compensation Commissioner when liability is accepted for payment of the claim. Where a W.Cl.56 is not issued, it usually indicates that the Compensation Commissioner has not accepted liability for any payment – in this instance the employee may have a claim against the employer. If the employee, however, disagrees with the decision of the Compensation Commissioner, an appeal may be lodged by the employee within 90 days by submitting form “W929” to the Compensation Commissioners’ office.

  1. If the work-related injury continues for a long time and where the employee is prolonged absent from work, the medical practitioner must send a progress medical report (“W.Cl 5”) to the Compensation Commissioner. The progress report should be submitted monthly until the employee’s condition is fully stabilised. This informs the Compensation Commissioner of the time period the employee is absent work.
  1. Once the medical practitioner handling the case is satisfied that the employee is fit to return to work, the practitioner will issue a final report that the employee is fit to return to work; or that the employee’s injury resulted in him/her being permanently disabled.  The medical practitioner must forward this report to the employer who will sends it to the Compensation Commissioner.
  1. When the employee resumes work, a resumption report (“W.Cl 6”) must be completed and submitted to the Compensation Commissioner. Only after every one of these forms has been submitted to the Compensation Commissioner, will payment be made of all of the medical and related disbursements, where after the case will be closed.

This article is a general information sheet and should not be used or relied on as legal or other professional advice. No liability can be accepted for any errors or omissions nor for any loss or damage arising from reliance upon any information herein. Always contact your legal adviser for specific and detailed advice. Errors and omissions excepted (E&OE)

References:

The Compensation for Occupational Injuries and Diseases Act, Act 130 of 1993

The South African Labour Guide

THE RIGHT TO PROTEST: WHAT EMPLOYEES SHOULD KNOW

The right to protest is an integral part of South Africa’s constitution and has recently come to the forefront with mass protest being organised across the country in response to President Jacob Zuma’s reshuffling of cabinet, and the subsequent downgrade of South Africa to junk status. It is also something which often comes under inspection by the people being protested against, as well as employers who raise questions regarding their employees’ right to protest during normal working hours.

Section 17 of the Bill of Rights in the Constitution entrenches the right of everyone, “peacefully and unarmed, to assemble, to demonstrate, to picket and to present petitions.”

Can employees protest during normal working hours?

If an employee of a private company wants to join a protest march during regular working hours, it is necessary that they clear it with their superior first.

  • Any absence from work that is not authorised by the employer constitutes misconduct and gives the employer the right to take disciplinary action against the employee.
  • The type of disciplinary action depends on the circumstances, but can include dismissal if the employer is able to show significant inconvenience caused as a result of the employee’s absence and/or if the absence was in defiance of an express instruction to attend work.

Despite this, the Labour Relations Act does give every employee who is not engaged in an essential service‚ the right to take part in protest action for the purpose of promoting or defending the socio- economic interests of workers.

Conclusion

It is also not a crime to attend a protest unless it has been prohibited and protests can only be prohibited in very specific circumstances. However, employees should confirm with their employers about taking time off to protest and employers should be reasonable about letting their employees protest, considering it is within their right to do so. However, all things that are otherwise illegal, such as violence, vandalism, arson or hate speech, are also illegal during a protest.

This article is a general information sheet and should not be used or relied on as legal or other professional advice. No liability can be accepted for any errors or omissions nor for any loss or damage arising from reliance upon any information herein. Always contact your legal adviser for specific and detailed advice. Errors and omissions excepted (E&OE) 

References:

http://www.timeslive.co.za/consumerlive/2017/04/05/Planning-to-skip-work-for-the-protests-on-Friday-Read-this-first

https://www.dailymaverick.co.za/article/2017-04-06-groundup-dont-fall-for-illegal-protest-nonsense/#.WOd7JIiGPIU

GOVERNMENT ADMINISTRATORS MAKING WRONG DECISIONS

Occasionally, government administrations make decisions that people don’t understand or agree with. In cases such as these there are procedures to follow that ensures administrative justice. The Promotion of Administrative Justice Act allows you to have a say in matters that affect your rights.

The Promotion of Administrative Justice Act of 2000 (PAJA) gives people the right to fair, lawful and reasonable administrative action. Furthermore, it gives the right for individuals to be provided with reasons for any administrative actions that affect them negatively.

Administrative action?

If a person applies for an ID, for example, home affairs has to decide on whether or not the person should get one. They could perhaps decide that an ID should not be granted. This process is an example of an administrative action.

Government departments, the police, the army and parastatals such as ESKOM all make up the administration. PAJA applies when a decision made by the administration has a negative effect on someone’s rights. Maybe someone has been denied a work permit, for example, and the administrator did not give specific or good reasons why. PAJA gives them right to know what the reasons were and why they were made.

What does PAJA do?

PAJA requires that administrative decisions follow fair procedures and it allows you to have a say before a decision is made with possible negative implications to your rights. Those who make administrative decisions also have to clearly explain their decisions and tell you about any internal appeals within their department. You are also allowed to ask a court to review their decision when it’s made. An important benefit of PAJA is that you can request the reasons for their decisions.

Know your rights

Administrators are not allowed to simply make decisions without consulting you in several ways first. First, they have to tell you what decisions they are planning to make and how they will affect you. They also have to give you enough time to respond to their plan.

When a decision has been taken and it has negatively affected your rights, administrators must give you a clear statement of what they decided and a notice of your right to review the decision. They also have to give you notice that you can request written reasons for their decision, which you should pursue if you believe an administrators decision was unreasonable or unlawful.

These are some reasons that would make an administrative decision unlawful:

  • There was no good reason for the decision.
  • The decision-maker was not authorised to do so by legislation.
  • The person who took the action applied the law incorrectly.

What can you do?

If a decision has been made that you believe contravenes your rights, you can request that the particular department provide reasons for the decision, if reasons have not already been given. The request should be in submitted in writing and within 90 days of the decision having been made. If you don’t agree with the decision or reasons, you can go through an internal appeal. This step must be taken before you can take further action. Government administrations will usually have their own internal appeals process, which they should notify you about. If you’re still not happy you can complain directly to the department involved or go to a court to take the matter further. Going to court is expensive so it’s advisable to settle the matter through internal appeals, if possible.

This article is a general information sheet and should not be used or relied on as legal or other professional advice. No liability can be accepted for any errors or omissions nor for any loss or damage arising from reliance upon any information herein. Always contact your legal adviser for specific and detailed advice. Errors and omissions excepted (E&OE)

Reference:

Promotion of Administrative Justice Act, 2000 (Act 3 of 2000) Department of Justice and Constitutional Development. Accessed: http://www.justice.gov.za/paja. 09/05/2016.

CAN I STILL GO TO THE CCMA AFTER I SETTLED?

If an employee has been demoted after a fair process and has accepted the demotion, could they still go to the CCMA for unfair labour practice. It’s important to first take into account the circumstances.

A case involving Builders Warehouse

The facts in Builders Warehouse (Pty) Ltd v Commission for Conciliation, Mediation and Arbitration and Others[1] can be summarised as follows: The employee worked as an Administrative Manager at Builders Warehouse (Pty) Ltd. She was informed by doctors that she was very ill and would most likely have to go to hospital frequently and take various types of medication. Over the next three years her absenteeism increased significantly and her employers became concerned as she was no longer able to do her job effectively, even when she was not absent, due to the side effects of her medication.

Builders Warehouse, after having discussions with the employee, suspended her pending an investigation into her capacity to undertake the functions of an administrative manager, taking into account her health and performance. Builders Warehouse held an incapacity hearing and the external chairperson ruled that, due to the employee’s excessive and increasing absenteeism, dismissal was the appropriate sanction. The chairperson, however, offered her a demotion instead of a dismissal. The employee accepted this demotion in writing.

After this agreement between Builders Warehouse and the employee was concluded, she obtained legal assistance and subsequently complained to the CCMA that Builders Warehouse had committed an unfair labour practice by demoting her.

The question here is whether the employee was entitled to refer an unfair labour practice dispute concerning the demotion to the CCMA.[2]

The arbitrator in the CCMA decided that because there was consent to the demotion, the CCMA did not have jurisdiction to hear the dispute. The employee then appealed to the Labour Court and once again to the Labour Appeal Court, of which the outcomes are set out below.

Outcomes of the case

The Labour Court and the Labour Appeal Court looked at Section 186(2)(a) of the Labour Relations Act[3] in this regard, which states:

“Unfair labour practice means any unfair act or omission that arises between an employer and an employee involving unfair conduct by the employer relating to the promotion, demotion, probation (excluding disputes about dismissals for a reason relating to probation) or training of an employee or relating to the provision of benefits.”

The Labour Appeal Court upheld the judgement in the Labour Court and found that although a binding contract comes into existence when employers and employees settle their differences by agreement, such an agreement does not mean that the CCMA does not have jurisdiction to hear the dispute. The fact that the parties have agreed that the employee accepted demotion is not a complete defence for the employer because the ambit of this unfair labour practice is wide enough to include the implementation of an agreement to accept demotion.[4] The Labour Appeal Court confirmed that the determination of whether a demotion took place, unlike the determination of dismissal, does not require an arbitrator to determine if there was consent or not.[5]

Conclusion

Although consent is a relevant issue in regard to the merits of a dispute regarding an unfair labour practice, it is not a jurisdictional prerequisite. This means that the CCMA does have the power to hear a matter relating to a demotion even though there was consent thereto.

This article is a general information sheet and should not be used or relied on as legal or other professional advice. No liability can be accepted for any errors or omissions nor for any loss or damage arising from reliance upon any information herein. Always contact your legal adviser for specific and detailed advice. Errors and omissions excepted (E&OE)

References:

Builders Warehouse (Pty) Ltd v Commission for Conciliation, Mediation and Arbitration and Others (PA 1/14) [2015] ZALAC

Labour Relations Act 66 of 1995

[1] (PA 1/14) [2015] ZALAC.

[2] (PA 1/14) [2015] ZALAC Par 12.

[3] Act 66 of 1995.

[4] Builders Warehouse (Pty) Ltd v Commission for Conciliation, Mediation and Arbitration and Others (PA 1/14) [2015] ZALAC Par 14.

[5] Builders Warehouse (Pty) Ltd v Commission for Conciliation, Mediation and Arbitration and Others (PA 1/14) [2015] ZALAC Par 13.

Basic Conditions of Employment

A1_B There are basic standards which are set out in the Basic Conditions of Employment Act 75 of 1997 which regulate, amongst other, the working hours that employees are permitted to work. Whether these conditions are enforced in practice, however, is uncertain.

The Basic Conditions of Employment Act 75 of 1997 (BCEA) sets certain minimum standards of working conditions for employees. In Section 1 and 3 the BCEA sets out that it does not apply to independent contractors, as well as certain others such as unpaid volunteers, members of the South African National Defence Force and South African National Secret Service. Conditions regulating working hours are included in the BCEA which, in addition to the general exclusions mentioned above, exclude the following persons:

  • Senior managers;
  • Sales staff who travel to the premises of customers and who regulate their own work hours;
  • Employees who work less than 24 hours a month for an employer;
  • Employees earning in excess of R 205 433.30 per annum.

If you do not fall into one of the abovementioned categories then the conditions in the BCEA (Sections 9 to 15) regulating working hours will apply to you.

The maximum amount of working hours per week are 45 hours. Those who work five days a week may work for 9 hours a day and those working six or seven days a week may work for 8 hours a day. These hours may be extended by agreement between an employee and employer but this extension is limited to a maximum of an extra 15 minutes per day or, alternatively, an extra 60 minutes per week.

A meal interval of at least 1 hour is due to an employee who works continuously for more than 5 hours and at this time the employee may only be asked to perform tasks that cannot be left undone or that cannot be entrusted to another employee. If the employee is required to work during a work interval, or if they are required to be available for work, that employee must be remunerated for being available during that time.

Overtime is limited to 10 hours per week if it is arranged per agreement between an employer and employee. This can, however, be increased to 15 hours a week by means of a collective agreement but this agreement is limited in duration in that it may not apply for more than 2 months in a 12 month period. The rate at which remuneration is calculated for overtime is at 1.5 times the employee’s normal remuneration.

These are some of the basic conditions regulating working hours, and further conditions and exceptions thereto can be found in Section 9 – 18 of the BCEA. Although the abovementioned conditions seem to provide protection to employees many employees will merely take note of them and continue to work overtime continuously without pay and without complaining. Unfortunately we live in a country where there are far more people to fill jobs than jobs available and therefore the only time that this Act is properly utilised is through collective bargaining and trade unions; therefore it offers little comfort to individual employees not belonging to trade unions.

Bibliography:

  • A C Basson, M A Christianson, A Dekker, C Gerbers, P A K Le Roux, C Mischke, E M L Strydom: Essential Labour Law 5th ed. (2009)
  • Basic Conditions of Employment Act 75 of 1997

This article is a general information sheet and should not be used or relied on as legal or other professional advice. No liability can be accepted for any errors or omissions nor for any loss or damage arising from reliance upon any information herein. Always contact your legal adviser for specific and detailed advice. Errors and omissions excepted (E&OE)

What constitutes fair dismissal?

A2_BLabour law emphasises that every employee has the right not to be dismissed unfairly. This law defines the meaning of dismissal and when it may lawfully occur. Substantive and procedural fairness determines whether the dismissal was fair.

Dismissal means the following: The termination of a contract of employment with or without notice, and also if the employer fails to provide a fixed-term contract, or he does renew the contract, but on less favourable terms than the employee had reasonably expected.

Section 188 of the Labour Relations Act provides that dismissal is fair if the employer can prove that the dismissal is related to the employee's conduct or capacity, or if it can be proven that the dismissal is based on the employer's operational requirements. Dismissal is usually fair if a fair procedure was followed. Good practices are set out in legislation which outlines the discharge processes and must be taken into account.

Labour legislation provides for three different types of discharge, namely dismissal due to misconduct, poor performance or operational requirements. Certain procedures must be followed for each type of discharge. Employers sometimes confuse misconduct with poor performance. It is very important that the correct procedure is followed, but it is also necessary that the cause of the unsatisfactory behaviour is determined.

Misconduct is when the employee has violated certain rules such as rules against dishonesty or theft, or has refused to obey reasonable and lawful instructions. In these situations the employee has decided not to honour the code of conduct. The employee has knowingly violated a rule and therefore the person should be disciplined. This may result in written warnings and/or possible dismissal.

In contrast, poor performance involves situations where the employee is not in deliberate violation of any regulations but it may involve circumstances over which the employee may not necessarily have control. In this case other factors could be the cause of poor performance, such as lack of resources, inexperience, inadequate training or poor health. It is clear that the employee is not directly responsible for the behaviour and therefore disciplinary actions cannot be taken. The employee cannot be blamed for something like illness, therefore a counselling process is followed in lieu of a disciplinary hearing in order to find solutions for the poor performance.

The last type of dismissal is due to operational requirements. This type of discharge has to do with economic conditions, including a shortage of work or a lack of money. These are cases where the employer can no longer afford to retain a certain number of employees or new computers or sophisticated equipment have been acquired which renders a number of employees redundant. These are factors beyond the control of the employee and involves steps that the employer takes to protect his or her business from being ruined financially.

It is very important that the process contained in section 189 of the Labour Relations Act be followed here. This process requires the employer to engage with the employee in a meaningful way in order to negotiate and disclose certain information before dismissal can take place.

This article is a general information sheet and should not be used or relied on as legal or other professional advice. No liability can be accepted for any errors or omissions nor for any loss or damage arising from reliance upon any information herein. Always contact your legal adviser for specific and detailed advice. Errors and omissions excepted (E&OE)

Can I still make a case of unfair labour practice if I have settled?

A4_BIn this article we will discuss whether, in the face of an agreement between an employer and an employee in terms of which an employee accepts a demotion to a lower position, the employee is nevertheless entitled to refer an unfair labour practice dispute concerning this demotion to the CCMA.

 

The facts in Builders Warehouse (Pty) Ltd v Commission for Conciliation, Mediation and Arbitration and Others[1] can be summarised as follows: The employee worked as an Administrative Manager at Builders Warehouse (Pty) Ltd. She was informed by doctors that she was very ill and would most likely have to go to hospital frequently and take various types of medication. Over the next three years her absenteeism increased significantly and her employers became concerned as she was no longer able to do her job effectively, even when she was not absent, due to the side effects of her medication. Builders Warehouse (Pty) Ltd, after having discussions with the employee, suspended her pending an investigation into her capacity to undertake the functions of an Administrative Manager, taking into account her health and performance. Builders Warehouse (Pty) Ltd held an incapacity hearing and the external Chairperson ruled that, due to the employee’s excessive and increasing absenteeism, dismissal was the appropriate sanction. The Chairperson, however, offered her a demotion instead of a dismissal. The employee accepted this demotion in writing.

After this agreement between Builders Warehouse (Pty) Ltd and the employee was concluded, she obtained legal assistance and subsequently complained to the CCMA that Builders Warehouse (Pty) Ltd had committed an unfair labour practice by demoting her.

The question here is whether, in the face of an agreement between Builders Warehouse (Pty) Ltd in terms of which the employee accepted demotion to a lower position, she was nevertheless entitled to refer an unfair labour practice dispute concerning this demotion to the CCMA.[2]

The arbitrator in the CCMA decided that because there was consent to the demotion, the CCMA did not have jurisdiction to hear the dispute. The employee then appealed to the Labour Court and once again to the Labour Appeal Court, of which the outcomes are set out below.

The Labour Court and the Labour Appeal Court looked at Section 186(2)(a) of the Labour Relations Act[3] in this regard, which states the following:

“Unfair labour practice means any unfair act or omission that arises between an employer and an employee involving –

unfair conduct by the employer relating to the promotion, demotion, probation (excluding disputes about dismissals for a reason relating to probation) or training of an employee or relating to the provision of benefits.”

The Labour Appeal Court upheld the judgement in the Labour Court and found that although a binding contract comes into existence when employers and employees settle their differences by agreement, such an agreement does not mean that the CCMA does not have jurisdiction to hear the dispute. The fact that the parties have agreed that the employee accepts demotion is not a complete defence for the employer because the ambit of this unfair labour practice is wide enough to include the implementation of an agreement to accept demotion.[4] The Labour Appeal Court confirmed that the determination of whether a demotion took place, unlike the determination of dismissal, does not require an arbitrator to determine if there was consent or not.[5]

In conclusion, it is clear from the Builders Warehouse case that, although consent is a relevant issue in regard to the merits of a dispute regarding an unfair labour practice, it is not a jurisdictional prerequisite. This means that the CCMA does have the power to hear a matter relating to a demotion even though there was consent thereto.

This article is a general information sheet and should not be used or relied on as legal or other professional advice. No liability can be accepted for any errors or omissions nor for any loss or damage arising from reliance upon any information herein. Always contact your legal adviser for specific and detailed advice. Errors and omissions excepted (E&OE)

Bibliography

  • Builders Warehouse (Pty) Ltd v Commission for Conciliation, Mediation and Arbitration and Others (PA 1/14) [2015] ZALAC
  • Labour Relations Act 66 of 1995

[1] (PA 1/14) [2015] ZALAC.

[2] (PA 1/14) [2015] ZALAC Par 12.

[3] Act 66 of 1995.

[4] Builders Warehouse (Pty) Ltd v Commission for Conciliation, Mediation and Arbitration and Others (PA 1/14) [2015] ZALAC Par 14.

[5] Builders Warehouse (Pty) Ltd v Commission for Conciliation, Mediation and Arbitration and Others (PA 1/14) [2015] ZALAC Par 13.

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