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National Union of Metal Workers of SA v BMW (South Africa) (Pty) Ltd

CitationCase No: JS 740/18
JurisdictionZA
Area of Law
Labour LawDismissal LawProcedural Law

Facts of the Case

The dispute concerned an alleged automatically unfair dismissal based on discrimination on the grounds of age. The dispute was referred to the CCMA for conciliation on 15 February 2018. The conciliation meeting was held on 13 July 2018, when a certificate of outcome was issued certifying the dispute remained unresolved. On 11 October 2018, the applicants referred the dispute to the Labour Court for adjudication. The respondent filed a special plea contending that the dispute was referred to the court out of time. The referral was made on the 88th day after the certificate was issued.

Legal Issues

  • Whether the dispute was referred to the Labour Court within the time limits prescribed by section 191 of the Labour Relations Act
  • Whether the 90-day period for referring disputes for adjudication under section 191(5)(b) runs from the date the certificate of outcome is issued or from the expiry of the 30-day period after the initial referral to the CCMA
  • Whether condonation was required for any alleged late referral

Judicial Outcome

1. The special plea is dismissed. 2. The registrar is directed to enroll the matter for trial. Each party was ordered to pay its own costs.

Ratio Decidendi

In the case of a dispute that is required to be referred for adjudication to the Labour Court under section 191(5)(b) of the LRA, section 191(11)(a) requires the dispute to be referred within 90 days of the issuing of the certificate of outcome by the CCMA or bargaining council certifying that the dispute remains unresolved, regardless of the date on which the 30-day period immediately following the date of referral of the dispute to the CCMA expired. The plain wording of section 191(11) draws a clear distinction between the processes of arbitration and adjudication, and the time limits applicable to each.

Obiter Dicta

The court observed that to the extent that the SAMWU v Ngwathe Local Municipality judgment made references to referrals for adjudication under section 191(5)(b), these were obiter dicta as that case dealt specifically with referrals to arbitration under section 191(5)(a). The court noted that the LAC in SAMWU did not refer to or explicitly overturn the Hernic decision. The court also commented that the absence of a corresponding provision for arbitration referrals may be anomalous, but the plain wording of section 191(11) must be given effect. The court also observed that if the Constitutional Court in F & J Electrical had considered that the date of expiry of the 30-day period post-referral was relevant, it would have said so.

Legal Significance

This case provides important clarification on the interpretation of section 191(11)(a) of the LRA regarding time limits for referring disputes for adjudication to the Labour Court. It distinguishes between the time limit requirements for referrals to arbitration (section 191(5)(a)) and referrals for adjudication (section 191(5)(b)), confirming that for adjudication referrals, the 90-day period runs from the date the certificate of outcome is issued, not from the expiry of the 30-day conciliation period. This provides certainty for employees and trade unions seeking to refer automatically unfair dismissal disputes to the Labour Court.

Cases Cited in This Judgment

  • F & J Electrical CC v MEWUSA obo E Mashatola and Others[2015] ZACC 3
    Applies

    The court applies the principle from this Constitutional Court judgment that the 90-day period for referring a dismissal dispute to the Labour Court for…

  • The South African Municipal Workers' Union National Provident Fund v Umzimkhulu Local Municipality and Others(297/2018) [2019] ZASCA 41
    Distinguishes

    The court distinguishes this case on the basis that it dealt with a referral to arbitration under s 191(5)(a), whereas the present case concerns a referral for…

Cited By 24 Cases

  • Association of Mineworkers and Construction Union and Others v Ngululu Bulk Carriers (Pty) Limited (In Liquidation) and Others[2020] ZACC 8
    Applies

    Court applies Intervalve's interpretation of section 157(4) of the LRA and section 191, holding that a certificate of non-resolution is sufficient proof that…

  • Bernert v Absa Bank Ltd(CCT 37/10) [2010] ZACC 28
    Applies

    Discussed the de minimis principle and the test for apprehension of bias in the context of judicial officer interest.

  • Carl Roberts v Additional Magistrate for the District of Johannesburg, Mr Van Den Berg and The Attorney General of the WitwatersrandCase No 548/97
    Applies

    Applied for the principle that the existence of a reasonable suspicion of bias satisfies the test and that an apprehension of a real likelihood of bias is not…

  • City of Tshwane Metropolitan Municipality v Vresthena (Pty) Ltd & Others(1124/2022) [2023] ZASCA 104 (22 June 2023)
    Applies

    Applied for the principle that section 34 of the Constitution does not explicitly provide for a right of appeal and that any implied right would be subject to…

  • Head of Department, Department of Education, Free State Province v Welkom High School and Others[2013] ZACC 25
    Cites

    Cited for the recognition of good faith consultation in labour dispute resolution.

  • Islamic Unity Convention v Minister of Telecommunications and Others(CCT 33/07) [2007] ZACC 26
    Applies

    Court applies the test for bias as formulated in BTR: whether a reasonable suspicion of bias exists.

  • Le Grange v The State(040/2008) [2008] ZASCA 102 (18 September 2008)
    Cites

    Cited for the principle that public confidence in the courts is important, and that the only guarantee of impartiality is conspicuous impartiality.

  • Lufuno Mphaphuli & Associates (Pty) Ltd v Andrews and Another; Lufuno Mphaphuli & Associates (Pty) Ltd v Bopanang Construction CC(CCT 97/07) [2009] ZACC 6
    Cites

    Cited for the principle that if a reasonable suspicion of partiality exists, the court cannot measure the extent of the risk.

  • National Credit Regulator v Dacqup Finances CC trading as ABC Financial Services – Pinetown and Another(382/2021) [2022] ZASCA 104 (24 June 2022)
    Follows

    Cited as endorsing Lord Devlin's test of reasonable suspicion.

  • National Union of Mineworkers and Motlhoki & Others v Mazista Tiles (Pty) Ltd(507/04) [2005] ZASCA 116 (23 November 2005)
    Follows

    Followed for the principle that leave to appeal to the SCA from the Labour Appeal Court is required, and that jurisdiction will only be exercised where there…

  • National Union of Mineworkers v Samancor Limited (Tubatse Ferrochrome)(625/10) [2011] ZASCA 74 (25 May 2011)
    Applies

    The court applies Fry's Metals' principle that this court will not interfere with a decision of the Labour Appeal Court only because it considers it wrong:…

  • Oosthuizen v Road Accident Fund(258/10) [2011] ZASCA 118 (06 July 2011)
    Applies

    This Court's inherent power to protect and regulate its own process does not extend to the assumption of jurisdiction not conferred upon it by statute.

  • Passenger Rail Agency of South Africa v Commission for Conciliation, Mediation and Arbitration and OthersCase no: C1037/18
    Cites

    The court cited the general rule that to determine what was conciliated, one must look at the 7.11 CCMA form and the certificate of outcome.

  • Raol Investments (Pty) Ltd t/a Thekwini Toyota v Zwelinjane Madlala(461/06) [2007] ZASCA 120
    Applies

    Court applies the test for leave to appeal to the Supreme Court of Appeal as articulated in this case.

  • Republican Press (Pty) Ltd v CEPPWAWU & Gumede and Others[2007] ZASCA 121
    Follows

    The court follows Fry's Metals, which held that the Constitution confers final appeal authority on the Supreme Court of Appeal in all non-constitutional…

  • Revon Adams v National Bargaining Council for the Road Freight and Logistics Industry and OthersCase no: C 700 / 16
    Applies

    Applied for the principle that service of a referral document must be direct and formal, putting the employer on notice of liability to legal consequences.

  • SACCAWU & Others v The President of the Industrial Tribunal & AnotherCase number 522/98 (Supreme Court of Appeal)
    Cites

    Cited for the principle that not only actual bias, but the outward appearance of bias, may vitiate the decision of a tribunal and that justice must be seen to…

  • Senkhane v The State(300/10) [2011] ZASCA 94 (31 May 2011)
    Applies

    Applied as authority that the SCA can, under its inherent power in section 173 of the Constitution, lay down a requirement for special leave to appeal from the…

  • South African Commercial Catering and Allied Workers Union and Others v Irvin & Johnson Limited Seafoods Division Fish Processing(CCT 2/00) [2000] ZACC 13
    Cites

    Authority quoted with approval in Sarfu stating that the law does not measure the amount of interest or apprehension; if suspicion is reasonably apprehended,…

  • South African Human Rights Commission on behalf of South African Jewish Board of Deputies v Masuku and Another[2022] ZACC 5
    Cites

    Cited as authority for the reasonable apprehension of bias test in recusal applications.

  • South African Reserve Bank v Leathern N O and Others(854/2020) [2021] ZASCA 102
    Applies

    Applied Lord Devlin's formulation of the meaning of 'suspicion' in assessing whether the Reserve Bank had reasonable grounds to block the accounts.

  • Take & Save Trading CC and Others v The Standard Bank of SA LimitedCase No 21/2003
    Related To

    Mentioned as an example of a case involving outside factors (whether an industrial court president could be unbiased after participating in management's…

  • The Competition Commission v Computicket (Pty) Ltd(853/2013) [2014] ZASCA 185 (26 November 2014)
    Follows

    Earlier judgment concerning similar provisions in s 183 of the Labour Relations Act, upon which American Natural Soda Ash relied; held this court derives…

  • Van Wyk v The State; Galela v The State(20273/2014; 20448/2014) [2014] ZASCA 152 (22 September 2014)
    Considers

    Case referred to in relation to questions about jurisdiction and the definition of 'appeal' under the Superior Courts Act.

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