YZ v State of Queensland (Department of Education)
[2025] QIRC 232
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- Unreported Judgment
- YZ v State of Queensland (Department of Education)[2025] QIRC 232
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YZ v State of Queensland (Department of Education)[2025] QIRC 232
YZ v State of Queensland (Department of Education)[2025] QIRC 232
QUEENSLAND INDUSTRIAL RELATIONS COMMISSION
CITATION: | YZ v State of Queensland (Department of Education) [2025] QIRC 232 |
PARTIES: | YZ (Appellant) v State of Queensland (Department of Queensland) (Respondent) |
CASE NO: | PSA/2025/137 |
PROCEEDING: | Public Sector Appeal – Suspension without pay decision |
DELIVERED ON: | 2 September 2025 |
DATE OF WRITTEN SUBMISSIONS: | Appeal Notice (14 July 2025) Respondent's submissions (28 July 2025) Appellant's submissions in reply (11 August 2025) Respondent's further submissions (18 August 2025) |
MEMBER: | Pidgeon IC |
HEARD AT: | On the papers |
ORDER: |
|
CATCHWORDS: | PUBLIC SECTOR – EMPLOYEES AND SERVANTS OF THE CROWN GENERALLY – PUBLIC SECTOR APPEAL – where the Appellant is employed by the State of Queensland (Department of Education) – where the Appellant is charged with a serious offence as defined in s 15 of the Working with Children (Risk Management and Screening) Act 2000 – where the decision-maker determined to suspend the Appellant without remuneration – where the Appellant appeals the decision to suspend without remuneration – where the appeal is dismissed – where the decision appealed against is confirmed |
LEGISLATION AND OTHER INSTRUMENTS: | Directive 06/23: Suspension cl 8 Education (Queensland College of Teachers) Act 2005 (Qld) s 50(4) Industrial Relations Act 2016 (Qld) s 562B(3), 562C(1) Public Sector Act 2022 (Qld) ss 91, 101 Working with Children (Risk Management and Screening) Act 2000 (Qld) s 15(1)(a) |
CASES: | BR v State of Queensland (No. 2) [2022] QIRC 154 Roche v State of Queensland (Queensland Ambulance Service) [2024] QIRC 230 |
Reasons for Decision
Introduction
- [1]YZ (hereafter 'YZ' or 'the Appellant') has been permanently employed as a primary school teacher since 16 February 2023. On 12 May 2025, YZ was arrested and charged by the Queensland Police Service with a 'serious offence' as defined in s 15(1)(a) of the Working with Children (Risk Management and Screening) Act 2000 ('Working with Children Act').[1]
- [2]On 13 May 2025, the Queensland Police Service provided written notice to the Queensland College of Teachers ('QCT') that the Appellant had been arrested and charged with a serious offence.[2]
- [3]On 13 May 2025, the Queensland College of Teachers notified the Respondent that pursuant to s 50(4) of the Education (Queensland College of Teachers) Act 2005, the Appellant's teacher registration had been suspended.[3]
- [4]At 3.57pm on 13 May 2025, YZ sent an email to the Principal of the school he works in, informing the Principal of the change to his registration status.[4]
- [5]On 21 May 2025, YZ was suspended from duty with pay. He was asked to show cause as to why he should not be suspended without remuneration and provided a response through his solicitors on 5 June 2025.
- [6]On 24 June 2025, Mr Damien Cricchiola, Executive Director, Integrity & Employee Relations, Human Resources (People) ('the decision-maker'), wrote to the Appellant and informed him of the following:
Pursuant to sections 101(1)(a) and 101(4) of the PS Act, and in accordance with clause 8 of the Public Sector Commission Suspension (Directive 06/23) (Suspension Directive), I have determined that it is not appropriate for you to be entitled to normal remuneration (pay) for the period of your suspension, which ends on 19 September 2025, for the reasons set out below.
- [7]The decision-maker then goes on to set out extensive reasons for the decision from pages 1 to 4 of the letter. The reasons for the decision are set out under the following headings: Liability to discipline under a disciplinary law; Nature of the discipline matter; Alternative duties; Factors not within the control of the department; and Fair and Reasonable. The decision also provides the Appellant with information about his appeal entitlements, a consideration of his human rights, a reminder of his obligation to disclose a charge or conviction of an indictable offence and the support which is available to him.
- [8]On 11 July 2025, YZ filed a Form 89 Appeal Notice. In Attachment A to that form, the Appellant sets out brief reasons for his appeal. In summary, YZ says that the decision was not fair and reasonable for the following reasons: failure to apply s 101 of the Public Sector Act 2022 ('the PS Act'); non-compliance with Directive 06/23 ('the Directive'); the decision was not fair and reasonable overall; and the decision is 'substantively unreasonable'. The Appellant then says that when his reasons for appeal are taken together, the decision to suspend him without remuneration is 'harsh, unfair and unreasonable'.
- [9]For the reasons set out in this decision, I have decided that the decision to suspend YZ without pay was fair and reasonable. The decision appealed against is confirmed.
Appeal principles
- [10]Section 562B(3) of the Industrial Relations Act 2016 ('the IR Act') provides that the appeal is to be decided by reviewing the decision appealed against and that 'the purpose of the appeal is to decide whether the decision appealed against was fair and reasonable'.
- [11]Findings made in the decision which are reasonably open on the relevant material or evidence before the decision-maker should not be expected to be disturbed on appeal.
- [12]A public sector appeal is not an opportunity for a fresh hearing, but a review of the decision arrived at by the decision-maker.
- [13]In deciding this appeal, s 562C(1) of the IR Act provides that the Commission may:
- confirm the decision appealed against; or
…
- For another appeal-set the decision aside, and substitute another decision or return the matter to the decision maker with a copy of the decision on appeal and any directions considered appropriate.
Consideration of YZ's Reasons for Appeal
First reason for appeal: failure to consider s 101 of the PS Act
- [14]Before a decision-maker may determine that an employee should be suspended without remuneration, they must be satisfied that the employee is liable to discipline under a disciplinary law.[5]
- [15]One of the Appellant's reasons for appeal is that the decision is not fair and reasonable as it fails to apply s 101 of the PS Act. YZ says that the decision-maker failed to consider how the statutory criteria under s 101 were met. The Appellant says that this failure to address the mandatory considerations makes the decision flawed and unreasonable.[6]
- [16]The Respondent notes that YZ has not provided any evidence or explanation as to how the decision failed to comply with s 101 of the PS Act.
- [17]The Respondent says that it is clear from the decision that the decision-maker has considered s 101(1)(a) and suspended the Appellant on the basis of a reasonable belief that the Appellant is liable to discipline under a disciplinary law.
- [18]The suspension decision states that the charges against YZ relate to a 'serious offence' pursuant to s 15 of the Working with Children Act. I do not know what the allegations against the Appellant are, but the Respondent says that they are 'entirely inconsistent with the standards expected of a public servant'.
- [19]The Respondent says that disciplinary action may be undertaken in relation to private conduct, where that conduct is improper or inappropriate and reflects seriously or adversely on the Department. The Respondent notes the Commission has found that the PS Act does 'not require there to be a causal nexus between the alleged conduct and the employment for a ground of discipline to exist'.[7]
- [20]The Respondent says that in forming the 'reasonable belief' that YZ was liable to discipline, the decision-maker considered the material from the QCT and the nature of the criminal charges. The Respondent says that it was 'clearly open' to the decision-maker to determine that the Appellant was liable for discipline in the circumstances and that in order to suspend pursuant to s 101(1), the decision-maker 'need not be satisfied that the employee has actually engaged in misconduct. Rather they only need to hold a reasonable belief that they have engaged in conduct, which if proven, would constitute misconduct'.[8]
- [21]In his reply written submissions filed on 11 August 2025, YZ accepts and acknowledges that he has been charged with criminal offences.[9] However, YZ states that the Respondent does not possess sufficient information to reasonably believe that he is liable to any form of disciplinary action. The Appellant's position is that he is not liable for disciplinary action at all and that he never will be.[10]
- [22]YZ says that the Department has relied solely on the existence of a single criminal charge and the consequential suspension of his teacher registration.[11] The Appellant maintains his innocence and says that there is 'significantly more to the matter than what may initially appear on the face of the charges'. YZ says that the allegation does not reflect the full circumstances of the situation.[12]
- [23]The Appellant argues that in order to be satisfied that he is liable to discipline, the Department must be in a position to evaluate the nature of the offence, the circumstances of the allegation and whether he is likely to be found guilty of the offence.[13]
- [24]
- [25]The Appellant asserts that he is entitled to the presumption of innocence and that the matter is in its very early stages and he has not received the full set of police material. YZ says that there is no certainty that the matter will proceed any further.[16]
- [26]The Appellant says that the suspension of the QCT registration is automatic based on the charges against him. He says that the QCT suspension decision is not a disciplinary outcome and does not represent a considered judgment about his conduct or suitability.[17]
- [27]YZ says that in relying on the QCT suspension of registration decision, the Department has abdicated its statutory responsibility to consider whether he is liable for discipline. The Appellant says that the 'Department must form its own reasonable belief about disciplinary liability based on evidence available to it, not assumptions or external administrative decisions made without regard to the Department's distinct disciplinary processes.[18]
- [28]The Respondent says that YZ's submission that the decision-maker formed a reasonable belief that he was liable for discipline only on the basis of the existence of the charges and the suspension of his teacher registration by the QCT is 'a gross oversimplification of the matter'.[19]
- [29]The Respondent submits that the threshold to suspend is different to that required to impose discipline. The Respondent points to its earlier submissions which have been canvassed above in support of this. The Respondent submits that it was 'ultimately open to the decision-maker to reasonably form a view that the employee was liable to discipline and having regard to the nature of discipline that the employee is liable, that this suspension be without remuneration.[20]
- [30]It seems to me that YZ has misunderstood or confused two different tests under the PS Act to be applied by decision-makers, that set out in s 101(1)(a): to reasonably believe that an employee is liable to discipline under a disciplinary law before moving to suspend the employee without pay; and the other test set out in s 91: before disciplining an employee, being reasonably satisfied that the employee is, for example, guilty of misconduct,[21] or contravening a standard of conduct in a way serious enough to warrant disciplinary action.[22] As s 91(2) sets out, 'a disciplinary ground arises when the act or omission constituting the ground is done or made'.
- [31]The Commission has previously considered that ss 101 and 91 'provide for suspension occurring before any findings are made, or indeed any substantial investigation has occurred'.[23] Section 91 anticipates a suspension without pay occurring on the basis that circumstances are such that if the allegation or charge is proven, the employee would be liable to discipline. The section clearly refers to a state of events in existence prior to any disciplinary finding being made. If a suspension without pay was reliant on a concluded disciplinary process, there would hardly be any need for a suspension without pay as a decision on disciplinary action to be taken would follow shortly thereafter.
- [32]I do not need to know what the charge is. It is sufficient for me to understand that the charge is a 'serious offence' as defined in s 15 of the Working with Children Act and that it has activated the suspension of his teacher registration. Given that the definition of misconduct set out in s 91(5) of the PS Act captures conduct in both an official capacity or alternatively 'a private capacity that reflects seriously and adversely on the public sector entity in which the employee is employed', I find that the existence of a serious criminal charge is sufficient to establish a reasonable belief that YZ is liable for discipline.
- [33]The Appellant's submissions to the effect that the Respondent cannot reasonably believe he is liable to discipline until all evidence is considered and he has been given a chance to defend himself are misguided. I also note that the decision-maker clearly states that no disciplinary finding has been made and that the suspension decision does not interfere with the Appellant's presumption of innocence.
- [34]I am satisfied that it was open to the decision-maker to form a reasonable belief that pursuant to s 101(1)(a), YZ is liable to discipline. The Appellant's first reason for appeal cannot succeed.
- [35]It follows that having satisfied s 101(1)(a), the decision-maker has satisfied s 101(4)(a) and it was open to them to move to the second limb of s 101(4) and consider whether it is not appropriate for the employee to be entitled to normal remuneration for the period of the suspension, having regard to the nature of the discipline to which the chief executive believes the employee is liable.
Second reason for appeal: Non-compliance with Directive 06/23
- [36]YZ's second reason for appeal says that the decision does not comply with the Directive. YZ sets out six 'factors' in cl 8 of the Directive which he says were not meaningfully considered by the decision-maker.
- [37]The Respondent notes that cl 8 of the Directive does not outline six factors that must be considered, but instead outlines that circumstances in which a chief executive may decide that that an employee is not entitled to normal pay for the period of the suspension are limited to where:[24]
- there are factors not within the control of the agency that are preventing the timely conclusion of the discipline process, for example if there are criminal charges and the investigation or discipline process is pending the outcome of these charges; or
- it is otherwise fair and reasonable to suspend an employee without remuneration, taking into account the financial impact on the employee and the border public interest of the employee remaining on suspension with remuneration.
- [38]With regard to cl 8(a), the Respondent says that the decision clearly outlines that the Appellant's criminal matters remain before the courts and states that serious criminal offences tend to result in protracted criminal proceedings.[25]
- [39]The Respondent also states that the decision outlines the decision-maker's consideration of cl 8.2(b) of the Directive. The Respondent points out that that the decision-maker specifically refers to the financial impact on YZ, and refers to the public interest in circumstances where there is a serious allegation and associated criminal charges arising.
- [40]The Respondent further notes that the Appellant was afforded procedural fairness and a show cause process regarding the proposed decision that he be suspended without pay, including an extension being granted for YZ to respond via his legal representatives.
- [41]I am satisfied that the decision-maker considered the matters set out in cl 8 (a) and (b). To this extent, the decision complied with the Directive. I understand YZ argues that these matters were not meaningfully considered. I will deal with those submissions here.
- [42]Firstly, I am satisfied that meaningful consideration was given to the matters set out in cl 8(a). There are factors outside of the control of the Department preventing the timely conclusion of the disciplinary process. In fact, the example given within that clause is reflected in the current circumstances, being that there is a criminal charge and the discipline process is pending the outcome of the charge. The five dot points set out under the heading 'Factors not within the control of the department' demonstrate that cl 8(a) has been properly addressed.
- [43]Having determined that cl 8.2(a) was satisfied, it was not incumbent upon the decision-maker to go on to consider cl 8.2(b). The decision-maker states on page 3 of the decision that 'for completeness' the decision-maker will go on to address the financial impact on YZ and the public interest of him remaining on suspension with pay.
- [44]The decision letter states that the decision-maker has carefully considered the financial impact the decision may have but goes on to state that this does not outweigh the seriousness of the criminal charge and that the charge may seriously diminish the public's confidence in the Department if he were to continue to be paid while the criminal proceedings remain on foot. The decision-maker states that he is 'satisfied that the public would agree that an employee responsible for student safety having been charged with serious criminal offences is an appropriate juncture to consider suspending the employee without remuneration'. The decision-maker explains that he has weighed the factors set out in cl 8.2(b) and determined that it is no longer appropriate for YZ to be paid by public funds while suspended.
- [45]I understand that suspension without pay will cause the Appellant significant financial hardship. I have also considered his submissions that he remains subject to financial obligations and cannot seek other employment.[26] I do not know why YZ believes he cannot seek other employment. The original suspension decision informed him of the process to be followed if he wished to seek alternative employment. The PS Act and the Directive clearly contemplate circumstances where an employee may be suspended without pay. There is nothing in the material before me to demonstrate that the decision-maker did not take the financial impact on the Appellant into consideration. It is open to YZ to seek alternative employment.
- [46]I understand that the Appellant considers the suspension without pay decision to be a punishment, and that it is 'extreme and unwarranted in light of the lack of probative evidence', however, the suspension without pay decision is not a disciplinary action and does not require 'probative evidence' prior to implementation. Disciplinary actions which may be implemented after grounds for discipline have been established are set out in s 92 and do not include suspension without pay.
- [47]YZ's second reason for appeal, being non-compliance with cl 8 of the Directive cannot succeed.
Third reason for appeal: The decision is not fair and reasonable overall
- [48]The Appellant sets out three reasons the decision is not fair and reasonable overall:
- Failure to consider why suspension with pay or alternative duties were not appropriate.
- [49]With regard to (a), I am satisfied that it has been adequately explained to YZ why the decision-maker determined that suspension with pay was not appropriate. With regard to consideration as to why alternative duties were not appropriate, I note that on 21 May 2025, in the initial suspension letter, YZ was informed that it was not appropriate for him to perform his substantive role of a classroom teacher at another location as his teacher registration had been suspended. The Appellant was informed that performing administrative duties, curriculum planning or project work was not reasonable or appropriate as his teacher registration had been suspended. That decision is not under appeal. The PS Act requires that consideration be given to alternative duties before a suspension occurs. It is not necessary to further consider alternative duties before making a suspension without pay decision. However, I note the Respondent's submissions that opportunities for the Appellant to undertake alternative duties were limited by his lack of QCT registration and the inability of the region to support other alternative roles.
- [50]While not contained in the decision letter, I accept the Respondent's submission that the Appellant is a relatively new teacher, and that this limits his ability with regard to other work such as curriculum planning.[27] It may be that more information could have been provided to YZ regarding the lack of alternative duties available to him, however this does not render the suspension without pay decision unfair or unreasonable.
- The reasons are vague and do not justify why suspension without pay necessary or proportionate in the circumstances
- [51]I have reviewed the decision, and I do not accept YZ's submission that the reasons provided are vague or fail to justify or explain why the decision was necessary. The decision did not need to address proportionality as it is not a disciplinary decision, however it does set out the serious nature of the matter and all the factors the decision-maker took into account. The decision-maker has provided detailed reasons as to why he considered it necessary, fair and reasonable to suspend YZ without pay.
- The decision-maker relies on reasons which are outside the statutory criteria and of limited relevance
- [52]The Appellant's reasons for appeal provide no further information as to what he means by this third reason the decision was not fair and reasonable. His further written submissions have not assisted me in determining what reasons outside of statutory criteria or of limited relevance have been relied upon.
- [53]YZ's third reason for appeal set out in his appeal notice cannot succeed.
Fourth reason for appeal: the decision is substantively unreasonable
- [54]In his appeal notice, the Appellant says that the decision to suspend him without pay is substantively unreasonable because it: is disproportionate to the nature of the alleged conduct; causes significant hardship and is made in circumstances where a less severe measure could have achieved the same administrative outcome. This fourth reason for appeal appears to repeat other submissions already dealt with above.
- [55]As I have previously noted at paragraphs [18] and [32], I do not know the specifics of the alleged conduct, however, I do know that the alleged conduct has given rise to a serious criminal charge against YZ of the type defined as a 'serious offence'.[28] The charge is of a serious enough nature that it has invoked a legislative requirement for the Appellant's teacher registration to be suspended. It is conduct of this nature that is contemplated by cl 8.2(a) of the Directive.
- [56]I accept that the decision has caused significant financial hardship for YZ. However, I am satisfied that this matter has been taken into consideration and weighed against the public interest. The legislation and the Directive clearly identify that there will be circumstances in which it is appropriate to suspend an employee without pay. I accept and agree with the Respondent's submissions that it is not controversial to place YZ on suspension without pay where:
- The nature of the charges is serious;
- YZ's QCT registration has been suspended;
- There is an inability to accommodate alternate duties;
- The public interest has been considered; and
- The nature of the discipline to which YZ may be liable
- [57]The Appellant's fourth reason for appeal cannot succeed.
Other matters
- [58]There is a dispute between the parties as to whether YZ notified the Respondent of the charge against him as required. The Respondent says that the Appellant waited until he had received correspondence from the QCT suspending his registration before informing his Principal that he had been arrested and charged with a 'serious offence' as defined in s 15 of the Working with Children Act. YZ disagrees and says that he 'provided full disclosure by way of an email notification to my principal within 24 hours of being charged'. I do not think this matter needs to be dealt with in reviewing the decision to suspend the Appellant without remuneration and I will not address these submissions further.
- [59]YZ complains that he has been underpaid as his Principal initially placed him on unpaid leave immediately despite having no authority to do so. The Appellant says that the resulting underpayment took many weeks to rectify, has not been fully rectified and that he remains out of pocket. The Respondent says that the matter has been addressed and that a review of YZ's pay records does not demonstrate that any outstanding payment exists. This matter is not within the scope of the appeal. If the Appellant believes that he has been underpaid, there are separate avenues available to him to pursue this.
Conclusion
- [60]YZ has been charged with a 'serious offence' resulting in the suspension of his teacher registration. I am satisfied that it was open to the decision-maker to reasonably believe that the Appellant is liable to disciplinary action under a disciplinary law.[29] As discussed above, forming such a reasonable belief is open to the decision-maker on the basis of the charge itself, and does not require the decision-maker to make disciplinary findings or be satisfied that the alleged conduct has occurred.
- [61]Having considered the table of 'serious offences' set out in s 15 of the Working with Children Act, I am satisfied that it was open to the decision-maker to believe that the nature of the discipline to which YZ is liable is at the more serious end of the disciplinary action contemplated by s 92 of the PS Act.[30] On that basis, it was open to the decision-maker to consider that YZ was not entitled to normal remuneration throughout the period of his suspension. The decision-maker then turned to considering the matters set out in the Directive.
- [62]The decision-maker was only required to be satisfied of one of the two circumstances set out in cl 8.2 of the Directive, however made the decision to consider both and provide reasons for his decision. Regarding cl 8.2(a), I am satisfied that it was open to the decision-maker to find that there were factors not within the control of the agency that are preventing the timely conclusion of the discipline process. In fact, the current circumstances are as set out in the example provided in cl 8.2(a), where there are criminal charges and the investigation or discipline process is pending the outcome of these charges.
- [63]While not necessary, the decision-maker then moved to consider cl 8.2(b). The decision demonstrates that the decision-maker considered the financial impact on the Appellant and the broader public interest of the Appellant remaining on suspension with remuneration. Reasons are provided by the decision-maker, including a conclusion that the financial impact on the Appellant does not outweigh public interest considerations.
- [64]YZ was provided procedural fairness, including an opportunity to show cause as to the proposed suspension without remuneration decision. The decision clearly communicates to YZ that 'no finding has been made, nor will be made, in relation to your alleged conduct the subject of the criminal charge against you until such time as you have been afforded an opportunity to respond'. No final decision has been made regarding disciplinary findings or outcomes and I am satisfied that the decision does not, as the Appellant suggests, undermine the presumption of innocence.
- [65]I am satisfied that prior to suspending YZ from duty, all reasonable alternative duties were considered. This is communicated to YZ in the original suspension decision of 21 May 2025. In circumstances where YZ's teacher registration was suspended and it was considered that there were no duties available to him. It was open to the decision-maker to move to suspension. I further note and accept the Respondent's submission that the nature of the criminal charges, meeting the criteria of 'serious offence' as defined in the Working with Children Act impacted on the reasonableness of alternative duties that do not involve direct contact with children. I further accept that the Appellant is relatively inexperienced, and this may have also impacted on the availability of roles that do not involve direct contact with children. The Chief Executive is required to manage 'the Department in a way that promotes the effective, efficient and appropriate management of public resources'.[31] While the Department is required to consider reasonable alternatives, it is not reasonable to expect the Department to invent unnecessary administrative or project-based roles.
- [66]I understand that the suspension without pay has created financial hardship for the Appellant, however he is not precluded from seeking alternative employment and I am satisfied that this was communicated to him in the initial suspension letter of 21 May 2025, including a direction that YZ is to notify his designated contact person if he engages in any alternative employment during his suspension period.
- [67]I am satisfied that the decision-maker has considered YZ's human rights, including considering that the decision does not limit YZ's human rights in criminal proceedings, and the right to be presumed innocent until proven guilty according to law.
- [68]The Appellant notes that although his QCT registration has been suspended, he remains an employee of the Respondent and his rights as a public sector employee have not been extinguished. I agree and am satisfied that the decision has been undertaken pursuant to the PS Act and the Directive. I also note that the Appellant has been allocated a contact person for communication during the period of his suspension and that he has also been provided with information about the Department's external Employee Assistance Program provider. YZ was appropriately informed of his appeal rights and has exercised those rights by way of this appeal.
- [69]For the reasons set out above, the decision of 24 June 2025 to suspend YZ without remuneration is fair and reasonable. I confirm the decision appealed against.
- [70]I make the following order:
Order
- The decision appealed against is confirmed.
Footnotes
[1] Respondent’s submissions filed in the Industrial Registry on 28 July 2025 [3]–[4].
[2] Ibid [5].
[3] Ibid [5]; Attachment A: the notice from the QCT.
[4] Ibid [5]; Attachment A, 2.
[5] s 101(1)(a) of the PS Act.
[6] Appeal Notice filed in the Industrial Registry on 14 July 2025.
[7] BR v State of Queensland (No. 2) [2022] QIRC 154, [51] (Hartigan DP); Respondent’s submissions (n 1) [15].
[8] Roche v State of Queensland (Queensland Ambulance Service) [2024] QIRC 230 [32]; Respondent’s submissions (n 1) [17].
[9] Appellant's written submissions in reply filed in the Industrial Registry on 11 August 2025 [1].
[10] Ibid [2].
[11] Ibid [5].
[12] Ibid [12].
[13] Ibid [27].
[14] Ibid [13].
[15] Ibid [15].
[16] Ibid [16]–[17].
[17] Ibid [30].
[18] Ibid [32].
[19] Respondent’s submissions in reply filed in the Industrial Registry on 18 August 2025 [14].
[20] Ibid [20].
[21] s 91(1)(b) of the PS Act.
[22] s 91(1)(h) of the PS Act.
[23] Roche v State of Queensland (Queensland Ambulance Service) [2024] QIRC 230 [33].
[24] Directive 06/23.
[25] Respondent’s submissions (n 1) [37].
[26] Appellant's written submissions in reply (n 9) [37]–[38].
[27] Respondent’s submissions (n 1) [43].
[28] s 15 of the Working With Children Act.
[29] s 101(1)(a) of the PS Act.
[30] s 101(4)(b) of the PS Act.
[31] s 177(1)(b) of the PS Act.