High Court Labour Division

High Court Labour Division is responsible for hearing and determining employment disputes. It was first inaugurated and launched in June 2007 under the Employment and Labour Relations Act.

98 judgments
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98 judgments
Citation
Judgment date
March 2022
Procedural defects in retrenchment (consultation/selection) warrant reduced compensation despite substantive fairness.
Employment law – retrenchment – procedural fairness – requirement to disclose information and consult unions/employee representatives; selection criteria and timing of consultation; computation of severance/leave pay; entitlement to 13th month pay; assessment of compensation for procedural unfairness.
31 March 2022
Failure to swear witnesses at the CMA vitiates proceedings, requiring the award to be nullified and retried before another arbitrator.
* Labour law – Commission for Mediation and Arbitration – evidence must be given under oath or affirmation – mandatory requirement under Rule 25(1) GN No.67/2007 and Oaths Act. * Evidence – failure to administer oath – omission vitiates proceedings and renders evidence valueless. * Remedy – nullification of CMA proceedings and remittal for retrial before another arbitrator.
31 March 2022
A revision filed after the six-week ELRA deadline is time-barred; court struck it out but granted leave to refile.
* Labour law – revision – time limits – section 91(1)(a) ELRA – six-week filing period; * Civil procedure – electronic filing – Judicature and Application of Laws (Electronic Filing) Rules, 2018; * Registry errors – wrong-registry e-filing does not cure statutory delay absent extension; * Remedy for late filing – dismissal generally, but court may strike out with leave to refile in interests of justice.
31 March 2022
Employer failed to prove employment terms; the applicant was unfairly terminated and awarded notice, salary and certificate.
Employment law – unfair termination – onus to prove termination and employment terms – employer’s duty to keep employee records (ELRA s.15) – proof of remuneration – entitlement to notice and certificate of service; unpleaded benefits not awarded.
31 March 2022
Silence to renewal notice does not automatically renew fixed‑term contracts; power of attorney did not permit testimonial substitution.
Labour law – fixed‑term contracts – renewal clause interpretation – silence does not amount to automatic renewal; Evidence — competency and admissibility — power of attorney does not authorise testimony for another; Pleadings — party bound by pleaded cause of action; Employment restructuring — employer’s legitimate reorganisation may justify altered contract terms.
31 March 2022
CMA award quashed for improper admission of electronic evidence and denial of the applicant's right to be heard; retrial ordered.
Labour law – CMA award – admission of electronic evidence – Electronic Transactions Act – right to be heard – apparent bias – procedural irregularity – nullification of proceedings – trial de novo.
31 March 2022
Retrenchment found substantively arguable but procedurally flawed; CMA award partially revised and reduced.
Labour law – retrenchment – substantive grounds (economic/COVID‑19) versus procedural fairness; consultation and notice requirements; admissibility and sufficiency of minutes/attendance as proof of consultation; assessment and revision of CMA compensation awards (meal allowance disallowed).
30 March 2022
Revision allowed where respondent became an independent contractor with a third party, so applicant not liable and CMA award quashed.
* Labour law – constructive dismissal – whether employee became an independent contractor with third party and whether constructive termination established. * Civil procedure – condonation – discretionary grant of extension of time by CMA and review on revision. * Evidence/procedure – improper recalling of a concluded witness without ruling; expungement of recalled evidence. * Contract law/employment – secondment/independent contractor clauses; third-party payment arrangements and necessity of joining third party to prove non-payment. * Relief – High Court quashes CMA award where essential party and contractual facts were not properly determined.
30 March 2022
30 March 2022
Applicant’s late, unsubstantiated reasons (illness and late judgment supply) did not justify extension of time to file a notice of appeal.
Extension of time to file notice of appeal; Court of Appeal Rules r.83(2) – thirty-day rule; submissions are not evidence; annexures must be to affidavit; medical proof not admissible when only attached to submissions; insufficient reasons for delay; application dismissed.
30 March 2022
Court found CMA lacked jurisdiction because the claimant was employed by the foreign parent, quashing the award.
Labour law — Jurisdiction of CMA — employment by foreign parent vs local entity; contractual forum/choice issues; resignation vs unfair termination; admissibility and analysis of documentary evidence; procedural compliance — new grounds in submissions and right to fair hearing.
30 March 2022
Court dismissed revision: dismissal was substantively and procedurally fair; no formal criminal charge barred disciplinary action.
Employment law; disciplinary dismissal; substantive fairness — balance of probabilities; procedural fairness — notice, representation, impartial panel, appeal; s.37(5) ELRA (inapplicable absent formal charge); s.102 ELRA — limited criminal jurisdiction.
29 March 2022
Failure to cite enabling statutory provisions and missing Section 91 time-limit renders the revision incompetent and time-barred.
Labour law – revision of CMA award; enabling provisions – Section 91 and Section 94, Employment and Labour Relations Act; time limit – six weeks (42 days) from service; mis-citation/non-citation of statutory provisions renders application incompetent; jurisdiction – striking out for being time-barred and improperly before the Court.
29 March 2022
CMA award quashed because termination dispute was filed after the 30‑day limit without condonation.
Labour law — limitation for termination disputes — Rule 10(1) GN No.64/2007 (30 days) — filing deadline and condonation; jurisdiction — effect of time‑bar on CMA jurisdiction; evidentiary weight of tribunal record; procedural irregularity — improper tendering/endorsement of exhibits; remedy — nullity and quashing of award when tribunal lacks jurisdiction.
29 March 2022
29 March 2022
Extension of time granted for leave application due to technical delay; alleged illegality not obvious on record.
Extension of time – Section 11(1) Appellate Jurisdiction Act; technical delay – time lost prosecuting incompetent application; illegality – must be obvious on face of record to justify extension; promptness after supply of ruling; requirement of leave to appeal in land matters under section 47(2) LDCA.
29 March 2022
Dismissal upheld as substantively and procedurally fair for post‑closure, unauthorized solicitation using employer facilities.
Labour law – Unfair dismissal – Substantive and procedural fairness; trade union representatives’ rights under section 60(3) limited by reasonable conditions; employer’s burden to prove misconduct on balance of probabilities; use of employer communication systems without authorization amounting to abuse of office.
28 March 2022
Revision application struck out for defective affidavit jurat naming the wrong deponent; leave granted to refile within seven days.
Labour Court procedure – Rule 24(1) and (3) GN No.106/2007 – notice of application must be supported by an affidavit; jurat of attestation – incorrect deponent named renders affidavit defective and application incompetent; strike out with leave to refile.
28 March 2022
Unfair termination claim held premature where resignation was evidenced and termination was not proved.
Employment law – unfair termination – claim premature where resignation—not proven termination—was evidenced; burden of proof on alleging party; CMA jurisdiction confined to pleaded reliefs.
28 March 2022
Probationary employees with under six months' service cannot bring unfair termination claims under section 35 ELRA; CMA lacked jurisdiction.
Employment law – probationary employment – application of section 35 ELRA excluding employees with less than six months' service from unfair termination claims – confirmation of employment not automatic – binding effect of Court of Appeal authority.
28 March 2022
Procedural bias by a disciplinary chair justified compensation, not re‑engagement, where dismissal was substantively fair.
* Employment law – Disciplinary procedures – Rule 13(4) Code – Chairperson must not have been involved in circumstances giving rise to the case; nemo judex. * Remedy for procedural unfairness – Re‑engagement inappropriate where dismissal is substantively fair; compensation under s.40(1)(c) proper. * Labour Court powers – Revising CMA award and substituting appropriate relief.
28 March 2022
Applicant failed to show sufficient cause or diligence; election-related network problems did not justify extension of time.
Labour procedure — extension of time under Rule 56(1) LCR — discretion exercised on sufficient cause (promptness, explanation, diligence) — network failure during elections not automatically excusing delay — failure to explain interluding delay fatal to extension application.
28 March 2022
Probationary employee unlawfully terminated without Rule 10 safeguards; CMA's eight-month award reduced to three months' salary.
Labour law – Probationary employment – Termination procedures under Rule 10 GN.42/2007 – Failure to notify performance concerns, failure to afford opportunity to respond or improve – Unfair termination; Compensation – appropriate quantum for probationary employee – reduction of award.
28 March 2022
Specific-task short-term contracts expiring on notice preclude unfair termination remedies and related compensation.
Labour law — specific-task/short-term contracts; conversion to permanent employment; legitimate expectation of renewal; unfair termination (s.35 Cap.366 R.E.2019) — advance notice of non‑renewal; review and quashing of CMA award for improper compensation.
28 March 2022
A CMA referral filed by a non-party and refiled without condonation is incompetent and renders the award void for lack of jurisdiction.
* Labour law – competence of referral – CMA F1 signed by non-party (legal officer) is incompetent and should be struck out. * Jurisdiction – time limits and condonation – re-filing without condonation after filing period renders proceedings incompetent. * Procedure – arbitrator’s powers – striking out incompetent referral vs curing/amending by ordering refile. * Relief – awards made in proceedings where CMA lacked jurisdiction are null and void.
28 March 2022
Applicant failed to prove lawful retrenchment; unfair termination compensation upheld but reduced for excess awards.
Labour law – retrenchment procedure (s.38 ELRA) – employer’s burden to prove fairness (s.39) – compensation for unfair termination additive to statutory payments (s.40) – limits on awards to pleaded claims; impropriety of considering unpleaded issues (sole breadwinner).
25 March 2022
Employer failed to follow statutory retrenchment procedure; terminations unfair and compensation adjusted on revision.
Labour law — retrenchment procedure — Section 38 (notice, disclosure, consultation) — burden on employer to prove fairness; Section 40 compensation in addition to statutory exit payments; appellate variation where CMA awards exceed pleaded claims or rely on unpleaded issues.
25 March 2022
Fixed-term employee unfairly retrenched where employer failed to prove and follow statutory retrenchment procedures; award revised.
Employment law – retrenchment – validity and proof of operational requirements; consultation and disclosure obligations under section 38 ELRA and GN 42/2007; late filing of respondent's pleadings – expungement and consequences; revision of CMA award for unfair termination.
25 March 2022
Fixed-term employment contracts cannot sustain unfair-termination remedies; written contract governs despite pronoun errors.
Employment law – fixed-term (specified) contracts v. unspecified-term contracts – entitlement to unfair-termination remedies; Evidence – primary weight of written contract; Interpretation – gender pronoun not fatal to contract validity; Labour procedure – review of CMA award for misapplication of law and failure to assess written evidence.
25 March 2022
25 March 2022
Application for revision dismissed for filing written submissions late without leave, equating to failure to prosecute.
Labour procedure — Revision application — Failure to file written submissions within time ordered by court — Orders to file submissions form part of hearing — Late submissions without leave are disregarded — Failure to prosecute/nonappearance — Dismissal as sanction.
25 March 2022
Termination found substantively and procedurally unfair; compensation, repatriation and subsistence awarded, reinstatement denied.
Employment law - unfair dismissal; substantive fairness (burden on employer); procedural fairness (right to be heard; notice requirements); remedies - reinstatement vs compensation; calculation of repatriation and subsistence; setting aside allowances lacking evidential support.
24 March 2022
Court granted condonation where medical evidence credibly explained 42-day delay, remitting dispute to CMA for hearing.
Labour law — condonation of late referral to arbitration — sufficiency of medical evidence to explain delay — standard for establishing 'sufficient cause' — remittal to CMA for hearing on merits.
24 March 2022
Retrenchment must be employer-initiated; employee conduct demonstrating handover and absence amounted to resignation.
Labour law — Retrenchment procedure — Retrenchment must be employer-initiated — Employee cannot 'opt' to trigger retrenchment; resignation by conduct — handing over duties and ceasing attendance — evidential effect; statutory retrenchment consultation under section 38 and GN No. 42/2007.
23 March 2022
Court quashed CMA restoration order for lack of evidence of sufficient cause and for arbitrator raising a new issue without hearing parties.
Labour law – restoration of proceedings dismissed for want of prosecution – sufficiency of cause for non-appearance; Procedural fairness – raising issues suo motu – requirement to place issues on record and afford parties opportunity to be heard; Civil procedure – improper preliminary objection raised in submissions without leave.
23 March 2022
A fixed-term employment contract ends on expiry absent proven termination or legitimate expectation of renewal.
* Employment law – Fixed-term contracts – Expiry versus termination – A fixed-term contract ends on its agreed expiry absent proven termination or legitimate expectation to renew. * Labour procedure – Scope of CMA issues – Arbitrator decides issues actually framed; no obligation to decide unframed breach claims. * Evidence – Written submissions are not evidence; awards must be based on evidence on record. * Legitimate expectation – Requires evidential basis; prior warning/underperformance undermines expectation of renewal.
22 March 2022
Court dismissed revision and upheld CMA award, finding dismissal unfair and compensation properly awarded.
* Employment law – unfair dismissal – substantive and procedural fairness – disciplinary hearing minutes and incapacity due to illness as defence; * Evidence – evaluation of witness testimony and documentary exhibits in disciplinary processes; * Remedies – compensation, notice in lieu and severance where dismissal found unfair; * Review – scope of court’s revision of CMA awards.
22 March 2022
Revision dismissed as time‑barred and meritless for failure to justify counsel's non‑appearance.
Labour law — Revision under s.91(1)(a) ELRA — Time limit for filing revision (six weeks) — Service/collection of award starts time running — Ex parte proceedings — Good cause for non‑appearance — Setting aside ex parte award — Procedural compliance and evidential sufficiency.
22 March 2022
Sickness and inability to afford a lawyer did not establish sufficient grounds for condonation of delay.
Labour law – Condonation of delay – Rule 11(3) GN No.64/2007 – requirement to account for each day of delay – sickness and seeking legal advice – adequacy of medical records and legal-service evidence.
21 March 2022
Court refused to reinterpret a clear CMA reinstatement order; applicant must refile competent execution to quantify arrears.
Labour law — Enforcement of CMA awards — Interpretation of arbitral awards — Reinstatement without loss of remuneration (s.40(1)(a) ELRA) — Quantification of arrears — Competence of execution proceedings against government — Requirement to refile proper execution application.
21 March 2022
Extension application struck out because the supporting affidavit was incurably defective and contradicted its annexures.
Affidavit evidence — material contradictions between affidavit and annexures — affidavit must be truthful — incurably defective affidavit renders supporting application incompetent — application for extension struck out.
21 March 2022
Extension application struck out due to supporting affidavit's contradictions, untruths, and failure to annex the relevant court order.
* Civil procedure — Application for extension of time — Supporting affidavit must state true, consistent facts — Contradictory statements and inconsistencies with annexures render an affidavit incurably defective — Failure to annex a relied-upon court order undermines evidential basis — Incompetent application struck out.
21 March 2022
Failure to renew a fixed‑term contract can be unfair termination if employees had an objective reasonable expectation of renewal.
Employment law – fixed‑term contracts – reasonable expectation of renewal; unfair termination; burden of proof in unfair termination claims; distinction between notice of termination and notice of non‑renewal; admissibility of electronic/documentary evidence in labour proceedings.
18 March 2022
CMA has jurisdiction over public corporation employee; improper award of prolonged subsistence and retirement benefits reversed.
Labour law – jurisdiction of CMA over employees of public corporations; distinction between public corporation and public service office; application of ELRA; statutory repatriation and subsistence allowance (s.43 ELRA); limits of collective agreement terms; entitlement to retirement versus termination benefits; compensation for unexpired period of fixed‑term contract renewed by default.
18 March 2022
Fixed-term contract expired by written terms; evidence did not establish reasonable expectation or automatic renewal.
* Employment law – fixed-term contract – requirement for written extension; interpretation of contractual clause limiting renewal. * Employment law – unfair termination – reasonable expectation of renewal under s.36(a)(iii) ELRA. * Labour practice – automatic renewal by default – Rule 4(3) GN No.42 of 2007 requires proof of continued performance. * Evidence – attendance at workplace alone insufficient; claimant must prove assignment and performance of duties. * Procedural – arbitrator’s findings supported by witness evidence; no extraneous facts introduced.
18 March 2022
High Court grants extension to file notice of appeal; application for memorandum extension premature without leave to appeal.
Appellate procedure – extension of time under s.11(1) AJA to lodge notice of appeal; competency of application for extension to file memorandum of appeal where appeal originates from District Land and Housing Tribunal – requirement to seek leave to appeal; sufficient cause—age, lack of legal representation and ignorance of procedure as grounds for extension.
18 March 2022
The applicant failed to prove the respondent's negligence; termination was unfair and the CMA award stands.
* Employment law – unfair termination – Section 37(2) Employment and Labour Relations Act – burden on employer to prove valid reason related to conduct and fair procedure; failure to prove duty and causal link to loss renders dismissal unfair.
18 March 2022
17 March 2022
16 March 2022
16 March 2022