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Selected cases

Federal Court of Australia · [2026] FCA 343

Hitachi Rail v Schoof

A Federal Court employment case about enterprise agreement construction, allowances, penalty rates and overtime payroll calculations.

Federal Court of Australia27 Mar 2026

Plain-English explainers, not legal advice. Check the linked official source before you rely on a specific section, and get advice for your situation.

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Quick read

  • Payroll rules should be converted into worked examples before a dispute starts.
  • A Federal Court employment case about enterprise agreement construction, allowances, penalty rates and overtime payroll calculations.

Use this to check

  • Enterprise agreement wording can materially change payroll calculations.
  • Allowances are not automatically included in base rates for penalties or overtime.
  • Declaratory relief may be refused where there is no live controversy.

Decision snapshot

  1. 1

    What happened

    • Neville Schoof was a former employee of Hitachi Rail STS Australia who worked as an electrician and communications technician.
    • His employment was covered by the Ansaldo STS Australia Pty Ltd Enterprise Agreement 2019.
    • The dispute concerned how penalty and overtime rates were calculated.
    • The issue was whether allowances under the agreement formed part of the base hourly rate used for penalty and overtime calculations, and whether a waiting time penalty provision applied to non-payment of allowances.
  2. 2

    What the court had to decide

    • The Court considered the proper construction of enterprise agreement provisions about penalty rates, overtime, base hourly rate and waiting time penalties, including whether allowances should be included in the base rate calculations.
  3. 3

    What the court decided

    • The Federal Court made declarations that, on the proper construction of the enterprise agreement, specified penalty and overtime calculations used the applicable hourly rate excluding allowances.
    • It declined waiting-time penalty declaratory relief as a matter of discretion.

Practical impact

Practical read

  • Payroll rules should be converted into worked examples before a dispute starts.
  • If an enterprise agreement uses terms like base hourly rate, allowances, penalties and overtime, payroll should know exactly which amounts are included.

Useful next steps

  • Enterprise agreement wording can materially change payroll calculations.
  • Allowances are not automatically included in base rates for penalties or overtime.
  • Declaratory relief may be refused where there is no live controversy.
  • Payroll configuration should be backed by documented legal interpretation and worked examples.
  • Translate enterprise agreement clauses into payroll examples before running payroll.

Practical read

This is a payroll interpretation case. The Court was not deciding whether every employee had been treated fairly in a broad sense. It was construing the words of a particular enterprise agreement and deciding whether allowances were included in the rate used to calculate penalties and overtime.

The Court accepted Hitachi's construction. The relevant base hourly rate was the applicable hourly rate in the schedule, excluding the allowances. The Court declined to give waiting-time declaratory relief because there was no longer a live controversy on that issue.

For employers, the practical lesson is to convert awards and enterprise agreements into payroll rules with examples. A payroll system should not guess whether an allowance flows into overtime, penalties, leave or termination payments. The legal team, payroll team and managers should be using the same interpretation before employees raise a dispute.

Checks to run

Key points

  • Translate enterprise agreement clauses into payroll examples before running payroll.
  • Document whether each allowance affects penalties, overtime, leave and termination payments.
  • Keep version control for payroll interpretation decisions.
  • Train managers not to promise pay outcomes inconsistent with the agreement.
  • Review payroll settings after a new award, agreement or classification change.

Key takeaways

  • Enterprise agreement wording can materially change payroll calculations.
  • Allowances are not automatically included in base rates for penalties or overtime.
  • Declaratory relief may be refused where there is no live controversy.
  • Payroll configuration should be backed by documented legal interpretation and worked examples.

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