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South Africa Judgment

Labour Court Cape Town

Mayisela v Commission for Conciliation Mediation And Arbitration and Others (C967/2014) [2015] ZALCCT 55 (5 August 2015)

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01

Holding and result

The court found that the Commissioner failed to discharge his duties by not summarising or analysing the oral and documentary evidence, despite the existence of a lengthy transcript. This omission contravened CCMA guidelines and rendered the award incapable of proper review. Without an evidentiary summary, the reviewing court could not answer the critical questions required by law, nor could it assess whether the Commissioner had made errors of fact or reached an unreasonable result. The court held that the only appropriate remedy was to set aside the award and remit the dispute for rehearing before a different Commissioner, in order to preserve the distinction between review and appeal and ensure procedural fairness.

Court disposition

The arbitration award is reviewed and set aside; the dispute is remitted to the CCMA for rehearing before a different Commissioner.

Orders

  • The award under case number NC1084-14 is hereby reviewed and set aside.
  • The dispute is remitted to first respondent to be heard by a commissioner other than second respondent.
  • The Registrar is directed to forward this judgment for the attention of the Senior Convening Commissioner of the CCMA, Northern Cape.
  • There is no order as to costs.

02

Material facts

Parties

Vincent Nkululeko Mayisela

Applicant Counsel: In person

Commission for Conciliation Mediation and Arbitration

Respondent

Theodorus Potgieter

Respondent

Legal Aid South Africa

Respondent Counsel: Advocate Suzanna Harvey

03

Procedural history

  1. Posture

    Review Application / Opposed Review of Arbitration Award Under Section 145 of the LRA

04

Questions and positions

Legal issues

Party arguments

Applicant
The applicant contended that the Commissioner failed to apply his mind to the evidence before him, did not summarise or analyse the oral and documentary evidence, and thus rendered an unreasonable award. The applicant argued that this failure prevented a proper review of the arbitration award and undermined the fairness of the process.
Respondent
The third respondent maintained that the dismissal was both procedurally and substantively fair, as found by the Commissioner. The respondent argued that the charges against the applicant were serious and supported by documentary evidence, and that the arbitration process was conducted in accordance with the applicable rules.

05

Court’s reasoning

  1. 01

    CCMA Guidelines for Misconduct Arbitrations (GN 602 of GG 34573 of 2 September 2011)

    A Commissioner must summarise and analyse both oral and documentary evidence in misconduct arbitrations to enable proper review.

  2. 02

    Gold Fields Mining SA (Pty) Ltd (Kloof Gold Mine) v Commission for Conciliation, Mediation & Arbitration & others (2014) 35 ILJ 943 (LAC) at paragraph 20

    A reviewing court must determine whether the Commissioner gave the parties a full opportunity to present their case, identified and understood the dispute, dealt with the substantial merits, and reached a reasonable decision based on the evidence.

  3. 03

    Herholdt v Nedbank Ltd (Congress of SA Trade Unions as Amicus Curiae) (2013) 34 ILJ 2795 (SCA) at paragraph 25

    Where a Commissioner fails to apply his mind to the evidence, the reviewing court cannot assess errors of fact or reasonableness of the result.

06

Ratio, limits and disposition

Ratio decidendi

The court found that the Commissioner failed to discharge his duties by not summarising or analysing the oral and documentary evidence, despite the existence of a lengthy transcript. This omission contravened CCMA guidelines and rendered the award incapable of proper review. Without an evidentiary summary, the reviewing court could not answer the critical questions required by law, nor could it assess whether the Commissioner had made errors of fact or reached an unreasonable result. The court held that the only appropriate remedy was to set aside the award and remit the dispute for rehearing before a different Commissioner, in order to preserve the distinction between review and appeal and ensure procedural fairness.

Obiter and limits

  • The court regretted that the parties' time, effort, and resources could not result in a final determination due to the Commissioner's procedural failures.
  • The judgment was forwarded to the Senior Convening Commissioner of the CCMA, Northern Cape, for attention.

Court disposition

The arbitration award is reviewed and set aside; the dispute is remitted to the CCMA for rehearing before a different Commissioner.

  • The award under case number NC1084-14 is hereby reviewed and set aside.
  • The dispute is remitted to first respondent to be heard by a commissioner other than second respondent.
  • The Registrar is directed to forward this judgment for the attention of the Senior Convening Commissioner of the CCMA, Northern Cape.
  • There is no order as to costs.

Source and reliance status

Labour Court Cape Town

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Judgment text

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Source document

Labour Court Cape Town

Judgment

[2015] ZALCCT 55

THE LABOUR COURT OF SOUTH AFRICA, CAPE TOWN

JUDGMENT

Not Reportable

Case Number C967/2014

In the matter between:

VINCENT

NKULULEKO

MAYISELA

Applicant

and

THE

COMMISSION FOR CONCILIATION

MEDIATION

AND

ARBITRATION

First Respondent

THEODORUS

POTGIETER

Second Respondent

LEGAL

AID SOUTH

AFRICA

Third Respondent

Date heard: 19 March 2015

Delivered: 5 August 2015

RABKIN-NAICKER J

[1] This is an opposed application to review an arbitration award under case number NC1084-14, which was handed down on the 8 October 2014. In terms of the award the dismissal of the applicant was found to be both procedurally and substantively fair.

[2] The applicant was employed by the third respondent (the Legal Aid Board) as its Justice Centre Executive at the time of his dismissal. The second respondent (the Commissioner) summarises the main charges against him in paragraph 12 of the Award of as follows:

“a) gross insubordination, b) gross insolence; c)attack on the honour dignity or good name of the ROE; d)threats and intimidation made via e-mail to the ROE; e) disruption of employer’s operations and activities; f) conduct resulting in or potentially damaging to the reputation of Legal Aid SA and/or bringing the name of Legal Aid SA into disrepute; g) irregular absence from office without proper leave, permission/notification; and h) transgression of the rules, regulations, policies and procedures of Legal Aid SA.”

[3] The Commissioner records the following at paragraph 16 of his Award:

“It is not necessary for me to summarize the evidence tendered by the parties as the evidence tendered is also captured in the documentary

evidence contained in the bundles in the form of e-mails, notices and minutes of meetings regarding re-instating Mr Hole at the Regional Court, which were read into the record and the respective witnesses examined on.”

[4] This abrogation of his duties as a Commissioner is made even more extraordinary if regard is had to the fact that there is a transcript of the oral evidence at arbitration which is well in excess of a thousand pages. The Commissioner has disregarded the relevant guidelines issued by the CCMA for misconduct arbitrations which duly include the need to summarise and analyse the oral and documentary evidence[1]. The result of this failure by the Commissioner is that the court cannot begin to properly perform its duties as a reviewing court.

[5] In a review application under section 145 of the LRA, the court must ask the following questions: (1) In terms of his or her duty to deal with the matter with the minimum of legal formalities, did the process employed by the commissioner give the parties a full opportunity to have their say? (2) Did the commissioner identify the dispute he or she was required to arbitrate? (3) Did the commissioner understand the nature of the dispute he or she was required to arbitrate? (4) Did the commissioner deal with the substantial merits of the dispute? (5) Is the commissioner's decision one that another decision maker could reasonably have arrived at based on the evidence? [2]

[6] However, with no summary of the evidence and no analysis of the evidence based on same contained in the award, a reviewing court

simply cannot answer the questions listed by the Labour Appeal Court above. Much of the grounds of review in this matter deal with the Commissioner’s alleged failure to apply his mind to the evidence before him. In these circumstances however, the court cannot assess if there have been errors of fact made by him and if so whether these led to an unreasonable result.[3]

[7] Unfortunately for the parties, I have no alternative but to remit this matter to be heard anew. To do otherwise would be to blur the critical distinction between an appeal and a review and in effect decide the matter on the merits de novo on the basis of the record before me. The parties have put much time, effort and resources into presenting their cases before the court and I regret that the matter could not be dealt with in the normal way.

[8] I therefore make the following order:

1. The award under case number NC1084-14 is hereby reviewed and set aside.

2. The dispute is remitted to first respondent to be heard by a commissioner other than second respondent.

3. The Registrar is directed to forward this judgment for the attention of the Senior Convening Commissioner of the CCMA, Northern Cape.

4. There is no order as to costs.

________

H. Rabkin-Naicker

Judge of the Labour Court

Appearances:

For the Applicant: In person

For the Third Respondent: Advocate Suzanna Harvey instructed by Legal Aid South Africa

[1] 23 GN 602 of GG 34573 of 2 September 2011.

[2] Gold Fields Mining SA (Pty) Ltd (Kloof Gold Mine) v Commission for Conciliation, Mediation & Arbitration & others (2014) 35 ILJ 943 (LAC) at paragraph 20.

[3] see Herholdt v Nedbank Ltd (Congress of SA Trade Unions as Amicus Curiae) (2013) 34 ILJ 2795 (SCA) at paragraph 25

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Authorities

Authorities used by the court

Cases, legislation, regulations, and constitutional provisions identified in the available record.

Gold Fields Mining SA (Pty) Ltd (Kloof Gold Mine) v Commission for Conciliation, Mediation & Arbitration & others (2014) 35 ILJ 943 (LAC)

Case cited

Herholdt v Nedbank Ltd (Congress of SA Trade Unions as Amicus Curiae) (2013) 34 ILJ 2795 (SCA)

Case cited

Labour Relations Act 66 of 1995

Legislation

Legislation referenced in the available case record.

CCMA Guidelines for Misconduct Arbitrations (GN 602 of GG 34573 of 2 September 2011)

Legislation

Legislation referenced in the available case record.

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