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Record W1550168670 · doi:10.17159/obiter.v32i3.12241

THE JURISDICTION OF THE LABOUR COURT IN INTERNATIONAL EMPLOYMENT CONTRACTS IN RESPECT OF WORKPLACES OUTSIDE SOUTH AFRICA

2021· article· en· W1550168670 on OpenAlex

Why this work is in the frame

A frame that forgets how it found something cannot be audited. These are the routes that admitted this work.

aboutThe title or abstract carries a Canadian signal from the geographic lexicon.
no affNo Canadian affiliation: this work is invisible to an affiliation-only frame.
No Canadian affiliation. An affiliation-only frame, the usual design, would never have seen this work. It is one of the works that make the case for inverting the frame.

Bibliographic record

VenueObiter · 2021
Typearticle
Languageen
FieldBusiness, Management and Accounting
TopicCorporate Governance and Law
Canadian institutionsnot available
Fundersnot available
KeywordsAdjudicationJurisdictionLawAppealLabour lawPolitical scienceConflict of lawsInternational lawPleading

Abstract

fetched live from OpenAlex

Does the Labour Court have jurisdiction to adjudicate disputes between a South African employer and a South African employee where the employee performs work for the employer in a foreign country? This is a question that should be considered, as one effect of globalisation is that South African employees are increasingly working for South African employers outside of South Africa. The difficulty is that the answer to the question is to be found in the area of private international law (conflict of laws) and that very few labour disputes involving private international law have been decided by South African courts. In 2002 in Kleynhans v Parmalat SA (Pty) Ltd (2002 9 BLLR 879 (LC)) and in 2005 in Parry v Astral Operations Ltd (supra) the Labour Court held that it did have the necessary jurisdiction to adjudicate disputes where the workplace was outside South Africa, provided that certain requirements are met. However, in Astral Operations Limited v Parry (2008 29 ILJ 2668 (LAC)) the Labour Appeal Court overturned the decision of the Labour Court. Zondo J reasoned that both the Labour Relations Act and the Basic Conditions of Employment Act do not have extra-territorial application in terms of the presumption against extra-territoriality and that, as the workplace was outside South Africa, the Labour Court, which was created by these two acts, did not have jurisdiction to adjudicate the matter. In this article I shall briefly discuss the four-stage private international law process of adjudication that should be followed in disputes where international employment contracts are involved. After that I shall discuss the judgments in Parry v Astral in the Labour Court and the decision in AstralOperations v Parry in the Labour Appeal Court as well as the effect of this decision. This will be followed by a discussion of the position regarding the jurisdiction of courts and tribunals adjudicating international employment disputes in the European Union, the United Kingdom and in Ontario, Canada. In conclusion, the judgment of the Labour Appeal Court in Astral Operations v Parry will be examined in the light of the constitutional right to fair labour practices and the necessity for employees to be protected in a globalised employment context in which multi-national enterprises operate across borders.

Fetched live from OpenAlex and de-inverted. Abstracts are not stored in this database: the inverted indexes are 8.6 GB of the frame’s 9.3 GB of text, and the host has 13 GB free.

Full frame distilled prediction

Teacher imitation

Not calibrated prevalence, not ground truth. Human validation pending. Learned from the 10,348 direct Codex labels and 10,348 direct Gemma labels. Candidate is the union of thresholded teacher heads; consensus is their intersection. These outputs are machine_predicted_unvalidated and are not human labels or direct frontier model labels.

metaresearch head score (Codex)0.000
metaresearch head score (Gemma)0.000
Version: codex-gemma-dda1882f352aValidation status: machine_predicted_unvalidated
Candidate categoriesnone
Consensus categoriesnone
DomainCandidate signal: none · Consensus signal: none
Study designCandidate signal: Observational · Consensus signal: Observational
GenreCandidate signal: Empirical · Consensus signal: Empirical
Teacher disagreement score0.226
Threshold uncertainty score0.143

Codex and Gemma teacher scores by category

CategoryCodexGemma
Metaresearch0.0000.000
Meta-epidemiology (narrow)0.0000.000
Meta-epidemiology (broad)0.0000.000
Bibliometrics0.0000.000
Science and technology studies0.0000.000
Scholarly communication0.0000.000
Open science0.0000.000
Research integrity0.0000.000
Insufficient payload (model declined to judge)0.0000.000

Machine scores (provisional)

The two teacher heads of the student model, read on this work. A score orders the frame for review; it never asserts a category, and the validation status ships verbatim with every row.

Baseline scores from an immature model (maturity gate not passed, 7 training rounds). Scores rank; they never assert a category.

Opus teacher head0.014
GPT teacher head0.213
Teacher spread0.200 · how far apart the two teachers sit on this one work
Validation statusscore_only:v0-immature-baseline · verbatim from the scoring run: score_only means the number may rank works, and no category label ships from it