Ruffley -v- Board of Management of St. Anne's School [2015] IECA 287 (08 December 2015)

Ruffley -v- Board of Management of St. Anne's School [2015] IECA 287 (08 December 2015)

The conduct of the employer, while flawed and procedurally unfair, did not constitute repeated inappropriate behaviour amounting to workplace bullying under the statutory definition. The disciplinary process was motivated by child protection concerns and lacked the sustained, malicious campaign required for bullying. The award for future loss of earnings was not supported by evidence or pleaded and must be set aside.

Citation
[2015] IECA 287
Parties
Respondent/plaintiff: Una Ruffley; Appellant/defendant: The Board of Management of St. Anne’s School
Jurisdiction
Ireland
Judgment Date
08 December 2015
Procedural Posture
Appeal / Court of Appeal Judgment
Outcome
Appeal allowed; High Court judgment set aside.
Legal Topics
Workplace Bullying, Duty of Care, Negligence, Disciplinary Procedures, Psychiatric Injury
Employment Law Tort Law Workplace Bullying Duty of Care Negligence Disciplinary Procedures Psychiatric Injury

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Parties

Una Ruffley

Respondent/plaintiff

The Board of Management of St. Anne’s School

Appellant/defendant

Procedural Posture

Appeal / Court of Appeal Judgment

Legal Issues

  1. 1 Whether the conduct of the employer constituted workplace bullying as defined by law
  2. 2 Whether the plaintiff suffered an identifiable psychiatric injury caused by the employer's conduct
  3. 3 Whether the award for future loss of earnings was appropriate

Ratio Decidendi

The conduct of the employer, while flawed and procedurally unfair, did not constitute repeated inappropriate behaviour amounting to workplace bullying under the statutory definition. The disciplinary process was motivated by child protection concerns and lacked the sustained, malicious campaign required for bullying. The award for future loss of earnings was not supported by evidence or pleaded and must be set aside.

Court Disposition

Appeal allowed; High Court judgment set aside.

Orders

  • Damages award set aside except for agreed loss of earnings up to trial date.
  • Future loss of earnings award (€47,000) set aside.