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South African Law • Jurisdictional Corpus
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W G Davey (Pty) Ltd v National Union of Metalworkers of South Africa

CitationCase No. 234/96 (SCA) delivered 26 March 1999
JurisdictionZA
Area of Law
Labour LawUnfair Labour Practice
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Dismissal

Facts of the Case

The appellant was a manufacturing company in the engineering industry. In August 1992, 25 of the appellant's hourly-paid employees, all NUMSA members, joined a national strike in the steel and engineering industry. On 25 August 1992, Myburgh J granted an interim interdict declaring the strike illegal. On 26 August, the appellant distributed a memorandum calling striking workers to return to work by 7 am on 28 August, failing which they would be dismissed. Only 12 workers arrived by the stipulated time. The remaining 13 employees were dismissed, and 6 of those who arrived but left to attend a NUMSA meeting at Hunter's Field Stadium were also dismissed. The meeting was called to consider the National Strike Committee's recommendation that workers return on Monday 31 August. All 19 dismissed employees reported for work on 31 August but were told they had been dismissed. NUMSA applied to the Industrial Court for a declaration of unfair labour practice, compensation, and reinstatement. The Industrial Court found the dismissals were not unfair, but the Labour Appeal Court reversed this on appeal, finding the dismissals constituted unfair labour practice and ordering reinstatement and compensation.

Legal Issues

  • Whether dismissal of employees following non-compliance with an ultimatum to return to work constituted an unfair labour practice
  • Whether the employer was required to consider new facts arising after the ultimatum was issued before implementing dismissals
  • Whether the employer's inflexible approach to the deadline for returning to work was fair in the circumstances
  • Whether reinstatement was an appropriate remedy

Judicial Outcome

The appeal was dismissed with costs. The order of the Labour Appeal Court was upheld with amendments: (1) dates in the LAC order were updated; (2) a new paragraph was added providing for deduction from amounts owing to workers of remuneration earned through employment from date of dismissal until recommencement with the appellant; (3) provision was made for arbitration under IMMSA in case of disputes regarding remuneration earned during the applicable period.

Ratio Decidendi

A dismissal will not necessarily be fair merely because a fair ultimatum is not complied with. Before implementing an ultimatum and dismissing employees, an employer must give careful consideration to new facts that may have arisen or circumstances that may have developed since the issue of the ultimatum, and must consider how the employees responded to the call to return to work. Dismissal is a drastic step and a 'course of last resort'. An employer who adopts an inflexible and intransigent attitude, deciding that a deadline is 'cast in stone' before it is even issued, and who refuses to consider significant developments occurring after the ultimatum was issued, acts unfairly in dismissing employees who fail to meet the deadline. The need for an employer to act with restraint may be even more important in cases of mass dismissals where the job security of a large number of workers is at stake.

Obiter Dicta

The Court observed that it would be unwise and undesirable to lay down any universally applicable test for deciding what is fair in unfair dismissal cases (citing Vetsak), noting that fairness is an elusive concept but unfair conduct can often be recognized when the concept is applied to specific facts. The Court commented on the problem of unnecessary documentation being included in the record on appeal, noting that while the explanation would be accepted in this case, future instances might result in punitive costs orders against offending parties or their attorneys. The Court noted that it is not sufficient for attorneys merely to attempt to reach agreement on what parts of the record should be excluded. The Court also observed that fairness must be considered from the viewpoint of both parties to a dispute, which is fundamental to achieving one of the objectives of the LRA - the preservation of labour peace.

Legal Significance

This case is significant in South African labour law for establishing important principles regarding the fairness of dismissals following ultimatums to striking workers. It clarifies that the fairness of an ultimatum and the fairness of dismissals pursuant to that ultimatum must be assessed separately. The judgment emphasizes that employers must exercise flexibility and consider new facts and changed circumstances that arise after an ultimatum is issued, particularly in the context of mass dismissals. The case reinforces the principle that dismissal is a 'course of last resort' and that employers cannot adopt rigid, inflexible approaches that close their minds to developing circumstances. It provides guidance on the duty of employers to act reasonably and with restraint, particularly where there are indications that employees may return to work within a reasonable timeframe. The case is part of a series of judgments arising from the August 1992 national strike that shaped South African labour jurisprudence in the period before the current Labour Relations Act 66 of 1995.

Cases Cited in This Judgment

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  • Atlantis Foundries (Pty) Ltd v NUMSA obo Morne BrownCase no: C867/2017
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  • Clement Roland Du Plessis v Public Protector: Adv Busisiwe Mkwebane and OthersCase no: C272/19
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  • Commercial Workers' Union of South Africa v Tao Ying Metal Industries(CCT 40/07) [2008] ZACC 15
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  • Department of Home Affairs v Public Servants Association and Others(CCT 148/16) [2017] ZACC 11
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    Cited for the principle that reinstatement is the fullest redress for unfair dismissal and restores the status quo ante.

  • Integrity Forensic Solutions CC v Amajuba District Municipality(662/2022) [2023] ZASCA 124 (28 September 2023)
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  • Johannes Wynand Louw Hofmeyr v Andre Saaiman t/a SA Endovascular Group PracticeCase no: C599/2017
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  • Merryweather v Scholtz and Another(447/2023) [2024] ZASCA 150 (6 November 2024)
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    Applied for the principle that special circumstances must be present to justify an appeal beyond reasonable prospects of success.

  • Meshack Phopo v National Commissioner of the South African Police Services and OthersCase No: P 275/16
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    Cited for the principle that legislation is to be interpreted textually, contextually and purposively.

  • Mpumelelo Obed Mbatha v University of Zululand(CCT 45/13) [2013] ZACC 43
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  • Murray, Glenville Frederick v The Minister of Defence(383/2006) [2008] ZASCA 44 (31 March 2008)
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    Applied for the reinstatement principle that an unfairly dismissed employee is entitled to restoration of the previous position absent countervailing reasons,…

  • Nampak Products (Pty) Ltd t/a Megapak v Commission for Conciliation, Mediation & Arbitration and OthersCase No: C 512/2018
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  • National Union of Metal Workers of South Africa and Others v Aveng Trident Steel (a division of Aveng Africa (Pty) Ltd) and Another[2020] ZACC 23
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    Cited on the prevalence of violence in strikes.

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  • National Union of Mineworkers and Motlhoki & Others v Mazista Tiles (Pty) Ltd(507/04) [2005] ZASCA 116 (23 November 2005)
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    Applied to construe the meaning of s 187(1)(c) as confined to conditional dismissals and not extending to irreversible dismissals, which construction was later…

  • National Union of Public Service & Allied Workers Union (NUPSAWU) obo Mani and Nine Others v National Lotteries Board(576/2012) [2013] ZASCA 63 (24 May 2013)
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  • Nhlapho and Others v Sasol Mining LtdJS 737/09 and JS 778/09, Labour Court of South Africa, Johannesburg (2019)
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    Cited for the proposition that the illegality of a strike is not a magic wand which automatically renders the dismissal of strikers fair.

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  • South African Transport and Allied Workers Union (SATAWU) and Dumisani Jama and 62 Others v Lebogang Michael Moloto N.O. and Jerry Sekete Koka N.O.(CCT 128/11) [2012] ZACC 19
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  • Strategic Liquor Services v Mvumbi, T NO and Others(CCT 33/09) [2009] ZACC 17
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    Applied by the Supreme Court of Appeal to establish the high threshold for granting leave to appeal from the Labour Appeal Court.

  • Stu Davidson and Sons (Pty) Ltd v Eastern Cape Motors (Pty) Ltd(260/2017) [2018] ZASCA 26 (23 March 2018)
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  • Tao Ying Metal Industries (Pty) Ltd v Pooe NO(222/06) [2007] ZASCA 54
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  • The Minister of Police and Another v Ramabanta(511/2024) [2025] ZASCA 95 (24 June 2025)
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  • The National Commissioner: Department of Correctional Services v Mnikwelwa NxeleCase no: DA04/2023 (LAC)
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  • Watson Kelemogile Lekalake v EOH Mthombo (Pty) LtdCase no: JS 895/19, Labour Court, Johannesburg
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