Ashton v The Corporation of the Trustees of the Roman Catholic Archdiocese of Brisbane & Heffernan [2025] QIRC 335

QUEENSLAND INDUSTRIAL RELATIONS COMMISSION CITATION: Ashton v The Corporation of the Trustees of the Roman Catholic Archdiocese of Brisbane & Heffernan [2025] QIRC 335 PARTIES: Ashton, Margaret (Complainant) v The Corporation of the Trustees of the Roman Catholic Archdiocese of Brisbane (First Respondent) & Heffernan, Cathy (Second Respondent) CASE NO: AD/2025/33 PROCEEDING: Application in existing proceedings DELIVERED ON: 5 December 2025 MEMBER: HEARD AT: Knight IC On the papers ORDER: Leave is granted for the First Respondent and Second Respondent to be legally represented pursuant to s 530(1)(c) of the Industrial Relations Act 2016 (Qld) CATCHWORDS: INDUSTRIAL LAW – QUEENSLAND – APPLICATION FOR LEGAL REPRESENTATION – where Respondents have applied for leave to be legally represented under s 530 Industrial Relations Act 2016 (Qld) – where Complainant opposes application – factors to be considered by the -- 1 of 14 -- 2 Commission in deciding whether to allow legal representation – circumstances of the case – leave granted for legal representation LEGISLATION: CASES: Acts Interpretation Act 1954 (Qld), sch 1 Anti-Discrimination Act 1991 (Qld) s 7, s 11, s 15, s 141 Legal Profession Act 2007 (Qld) Industrial Relations Act 2016 (Qld) s 529, s 530 Industrial Relations (Tribunals) Rules 2011 (Qld) Hassan v Queensland (Queensland Fire and Emergency Services) [2024] QIRC 167 National Tertiary Education Industry Union v Monash University [2016] FWC 5539 Rolph v State of Queensland (Department of Energy and Public Works) [2024] QIRC 188 Sillay v State of Queensland (Queensland Corrective Services) [2024] ICQ 16 State of Queensland (Department of the Premier and Cabinet) v Dawson [2021] QIRC 118 State of Queensland (Queensland Health) v Hume [2022] ICQ 001 State of Queensland v Dodds [2021] ICQ 007 Wanninayake v State of Queensland (Department of Natural Resources and Mines) [2014] QIRC 079 -- 2 of 14 -- 3 Reasons for Decision [1] On 9 April 2025, Ms Margaret Ashton ('the Complainant') made a complaint to the Queensland Human Rights Commission ('the QHRC') alleging that The Corporation of the Trustees of the Roman Catholic Archdiocese of Brisbane ('the First Respondent') and Ms Cathy Heffernan ('the Second Respondent') had contravened various provisions of the Anti-Discrimination Act 1991 (Qld) ('the AD Act'). [2] The Complaint was accepted by the QHRC under s 141 of the AD Act.1 On 16 June 2025, the QHRC referred the complaint to the Commission.2 [3] The Respondents have since applied for orders to be granted leave to be legally represented, pursuant to s 530 of the Industrial Relations Act 2016 (Qld) ('the IR Act'). 3 [4] The Complainant objects to leave being granted to the Respondent to be legally represented.4 [5] This decision is the determination of whether leave should be granted. Legislative Framework [6] Chapter 11, part 5, division 3 of the IR Act, headed 'Conduct of proceedings,' contains ss 529 and 530. [7] Section 529 of the IR Act deals with representation of parties generally in proceedings before the Queensland Industrial Relations Commission and relevantly provides: 529 Representation of parties generally (1) A party to proceedings, or a person ordered or permitted to appear or to be represented in the proceedings, may be represented in the proceedings by— (a)a lawyer, only in accordance with section 530 [8] Section 530 of the IR Act addresses the issue of legal representation5 and relevantly states:6 1 Anti-Discrimination Act 1991 (Qld) ('the AD Act') ss 7(h), 11, 15. 2 Referral of a Matter filed 16 June 2025. 3 Form 101 – Application for leave to be represented by a lawyer in certain proceedings filed 3 July 2025 ('Application for leave to be legally represented') and Form 20 – Affidavit of Cathy Heffernan filed 3 July 2025. 4 Form 102 – Response to application for leave to be represented by a lawyer in certain proceedings filed 3 July 2025 ('Objection to application for leave to be legally represented') and Form 20 – Affidavit of Margaret Ashton filed 3 July 2025. 5 A lawyer means an Australian lawyer within the meaning of the Legal Profession Act 2007 (Qld); Acts Interpretation Act 1954 (Qld) sch 1 (definition of 'lawyer'). 6 State of Queensland v Dodds [2021] ICQ 007 [37]. -- 3 of 14 -- 4 530 Legal representation … (1) A party to proceedings, or person ordered or permitted to appear or to be represented in the proceedings, may be represented by a lawyer only if— … (c) for proceedings before the commission, other than the full bench, under the Anti- Discrimination Act 1991—the commission gives leave; or … (4) An industrial tribunal may give leave under subsection (1) only if— (a) it would enable the proceedings to be dealt with more efficiently, having regard to the complexity of the matter; or (b) it would be unfair not to allow the party or person to be represented because the party or person is unable to represent the party's or person's interests in the proceedings; or (c) it would be unfair not to allow the party or person to be represented having regard to fairness between the party or person, and other parties or persons in the proceedings. [9] The discretion vested by s 530(1)(c) is limited by s 530(4) and the three discretionary factors identified in s 530(4)(a), (b) and (c). The effect of s 530(4) is that the Commission may grant leave only if: • it would enable the proceedings to be dealt with more efficiently, having regard to the complexity of the matter; or • it would be unfair not to allow the party or person to be represented because the party or person is unable to represent the party's or person's interests in the proceedings; or • it would be unfair not to allow the party or person to be represented having regard to fairness between the party or person, and other parties or persons in the proceedings. [10] The construction of s 529 and s 530 and the circumstances upon which a lawyer may appear before the Queensland Industrial Relations Commission were recently considered by President Davis in Sillay v State of Queensland (Queensland Corrective Services) ('Sillay'),7 when his Honour observed:8 [30] Section 529(1)(a) prohibits representation of a party by a lawyer except in accordance with s 530. By s 530(1)(e), proceedings before the QIRC may involve legal representation only by leave. The bases upon which leave may be given are prescribed by s 530(4). 7 [2024] IQC 16. 8 Ibid [30] – [38]. -- 4 of 14 -- 5 [31] The circumstances upon which a lawyer may appear before the QIRC are governed by ss 529 and 530 of the Act. If the discretion arises under s 530(4) to give leave to a party to be represented by a lawyer, then the discretion falls to be exercised. There are no presumptions as to how the discretion is exercised. However, no executive or judicial discretion vested by an Australian statute is unfettered. The discretion is limited and circumscribed by the purpose for which it was bestowed. [32] Section 530 has a typical structure. The factual circumstances prescribed by each of ss 530(4)(a), (b) and (c) are jurisdictional facts, the establishment of which empowers the QIRC to exercise a discretion to grant leave to a party to be legally represented. [33] Subsection (4)(a) requires the QIRC to be satisfied that legal representation “would enable the proceedings to be dealt with more efficiently” if lawyers represent a party. However, that assessment is limited. It is conducted “having regard to the complexity of the matter”. [34] The “matter” is the controversy the subject of the principal proceedings. The “proceedings” are the principal proceedings, namely the application for final relief. [35] The task then is to: (a) identify the complexity; and (b) identify how, “having regard to the complexity”, having a party represented by lawyers would “enable the proceedings to be dealt with more efficiently”. [36] Each of ss 530(4)(b) and 530(4)(c) concern an assessment of fairness. However, the assessment to be conducted under each of the two subsections is quite different. [37] Section 530(4)(b) requires an assessment only of the position of the applicant for legal representation. Legal representation “may” be allowed where it would be unfair to deny it “because the party or person is unable to represent the party’s or person’s interests in the proceeding”. Therefore, the first question is whether the party or person is “unable to represent [their] interests in the proceedings”. If the answer to that question is in the affirmative, then the use of the word “because” requires a causal connection to be established between the inability of the person to represent themselves and any unfairness in not allowing representation. [38] Section 530(4)(c) requires consideration of the respective positions of the parties to the proceedings. Legal representation “may” be allowed where it would be unfair not to allow legal representation to the party. However, as with s 530(4)(a), the assessment is limited. The assessment of whether it would be “unfair” is made “having regard to fairness between the party or person, and other parties or persons in the proceedings”. [11] The construction of s 530(4)(a) of the IR Act and the circumstances in which a party may be granted leave to be represented in proceedings by a lawyer in this Commission were also helpfully considered by Deputy President Merrell in State of Queensland (Queensland Health) v Hume ('Hume'),9 when his Honour observed:10 9 [2022] ICQ 001 ('Hume'). 10 Ibid [34] – [44], citing Brisbane South Regional Health Authority v Taylor (1996) 186 CLR 541, R v Workers' Compensation Board of Queensland ex parte Heffernan [1979] Qd R 563, NOM v DPP (2012) 38 VR 618, Warrell v Walton (2013) 233 IR 335, Fitzgerald v Woolworths Ltd (2017) 270 IR 128, and R v Trebilco; Ex Parte F. S. Faulkner & Sons Ltd (1936) 56 CLR 20. -- 5 of 14 -- 6 [34] First, the purpose of the combined effect of s 530(1)(a)(ii) and s 530(4) of the IR Act is to confer on the Court discretion to give leave, for a party or person ordered or permitted to appear or to be represented in proceedings before it, to be represented by a lawyer if the Court forms one of the value judgments in s 530(4)(a) to (c). [35] Secondly, it is clear that the power conferred on the Court is discretionary and not obligatory. The use of the verb 'may' in s 530(4) of the IR Act logically imports an element of discretion on the part of the Court. The discretionary character is not displaced by the mandatory requirement that the Court must form a value judgment about whether, relevantly to the present case, the giving of the leave sought would enable the proceedings to be dealt with more efficiently, having regard to the complexity of the matter. That is to say, if the Court forms that value judgment, then there is still a discretion to be exercised. The formation of one of the value judgments in s 530(4)(a) to (c) does not dictate that the discretion is automatically exercised in favour of an applicant seeking leave to be represented by a lawyer. [36] Thirdly, s 530(4)(a) of the IR Act refers to the question of whether leave would enable '… the proceedings' to be dealt with more efficiently, having regard to the complexity of '… the matter.' [37] Chapter 11, pt 5, div 3 of the IR Act is headed 'Conduct of proceedings.' Division 3 contains s 529 and s 530 of the IR Act. Section 529(1) of the IR Act provides that a person or party may be represented in the proceedings by an agent appointed in writing or, if the party or person is an organisation, an officer or member of that organisation. In s 529(2)(a) of the IR Act, the noun 'proceedings' is relevantly defined to mean proceedings under the IR Act or another Act being conducted by the Court, the Commission, an Industrial Magistrates Court or the Registrar. The noun 'proceedings' is relevantly defined in the same way in s 530(7) of the IR Act. [38] Having regard to that context, when s 530(4)(a) of the IR Act refers to '… the proceedings', my opinion is that phrase, relevantly to matters such as the present, refers to an application for relief made by a person which an industrial tribunal has jurisdiction to grant. [39] By contrast, s 530(4)(a) of the IR Act then refers to the complexity of '… the matter.' Because of the different phrase used, my opinion is that '… the matter' is a reference to the particular controversy or controversies requiring determination by the industrial tribunal so as to make a decision about the application for relief or, put another way, to determine the proceedings. [40] Fourthly, s 530(4)(a) of the IR Act is otherwise to be construed according to the ordinary meaning of the words used in that provision. A value judgment has to be formed as to whether or not the giving of leave to a party or person to be represented by a lawyer would enable the proceedings to be dealt with more efficiently, having regard to the complexity of the matter. The matter does not have to be complex, or compared to other matters that have or may become before the Court, be more complex; but regard must be had to the complexity of the matter. [41] Further, in having regard to that complexity, a judgment has to be formed as to whether allowing the party or person to be represented by a lawyer would enable the proceedings to be dealt with more efficiently. Section 530(4) of the IR Act is relevantly concerned with whether or not discretion should be exercised in favour of a party seeking leave to be represented by a lawyer in proceedings before the Court. As a consequence, my opinion is that the adverb 'efficiently', in the context that it is used in s 530(4)(a) of the IR Act, is concerned with, at least, timeliness. -- 6 of 14 -- 7 [42] Fifthly, if the Court forms one of the value judgments in s 530(4)(a) to (c) of the IR Act, s 530 is otherwise silent as to the factors the Court must consider in terms of exercising the discretion. In such a case, the relevant considerations must be determined from the scope and object of the provision conferring the discretion. [43] The object of s 530 of the IR Act is to set out the circumstances by which a party or person may be represented in the proceedings by a lawyer. The circumstances described in s 530(4), which enliven the discretion of the Court to give leave, concern efficiency in the conduct of the proceedings. The circumstances also concern fairness, having regard to the particular circumstances of the person or party seeking leave to be represented by a lawyer, and also fairness having regard to the other parties or persons in the proceedings. [44] As a consequence, depending on the circumstances of a particular case, matters such as efficiency and, or in the alternative, fairness, may be relevant considerations as to whether or not the discretion, once enlivened, should be exercised. Should the Respondent be granted leave to be legally represented? [12] The first issue in determining whether leave should be granted involves considering whether the matter is sufficiently complex such that legal representation would assist efficiency. [13] With respect to s 530(4)(a), the Complainant, Ms Ashton, submits that the matter is not of a legal complexity that would justify leave being granted for the Respondents to be legally represented. The reasons for this include: a) The complaint concerns issues, such as discrimination, workplace injury, and procedural fairness, which are routinely considered by the Commission;11 b) The issues in dispute, while important, are not so complex that legal representation is necessary for the Respondents;12 c) The Complainant has prepared submissions and materials which clearly outline the sequence of events supported by documentary evidence.13 Further, the factual and procedural matters in dispute are within the Complainant's capacity to explain clearly and the Complainant will continue to assist the Commission efficiently and respectfully;14 and d) The involvement of external legal representatives will introduce additional layers of formality, prolong hearings, and increase the procedural burden on the Complainant as a layperson.15 11 Complainant's Further Submissions filed 21 July 2025 ('Complainant's Further Submissions') [5]. 12 Objection to application for leave to be legally represented (n 4) [4]. 13 Complainant's Further Submissions (n 11) [4]. 14 Affidavit of Margaret Ashton filed 3 July 2025 ('Affidavit of Margaret Ashton') [5]. 15 Complainant's Further Submissions (n 11) [5]. -- 7 of 14 -- 8 [14] The Respondents submit that the matter is complex, both factually and legally, and that such complexity can be more efficiently and appropriately addressed with the assistance of legal representation.16 The Respondents submit that these complexities include but are not limited to the following: a) The interplay between the IR Act and the AD Act;17 b) The complex legal issues raised by the matter including with respect to the requirements under the AD Act;18 c) The allegations are made against several employees of the First Respondent, including the Head of Human Resources, who is named as a Respondent in the proceedings. In addition, several of the First Respondent's employees may be required to give evidence, and the presence of legal representation would assist in mitigating the potential for internal conflict;19 and d) The factual disputes in the matter require careful legal analysis to ensure efficient proceedings, including with respect to adducing evidence.20 [15] The Respondent further submits that the Applicant has sought legal assistance in the proceedings, including during the complaint process before the QHRC. This, it is submitted, supports the position that the matter involves inherent complexities.21 [16] In support of its application, the Respondents rely on the Fair Work Commission decision in National Tertiary Education Industry Union v Monash University,22 which considered the application of s 596(2)(a) of the Fair Work Act 2009 (Cth). The Respondents submit that s 596(2)(a) is largely consistent with s 530(4)(a) of the IR Act. In that decision, it was observed that:23 ... whether the matter could be dealt with more efficiently taking into account the complexity of the matter. The matter does not have to be complex per se or reach some threshold level of complexity before permission might be considered. The test is one of efficiency taking into account the complexity that is in the matter. (emphasis added) 16 Application for leave to be legally represented (n 3) [11]. 17 Ibid [12]. 18 Respondents' Further Submissions filed 31 July 2025 ('Respondents' Further Submissions') [8](a). 19 Application for leave to be legally represented (n 3) [13]; Respondent's Further Submissions (n 18) [13](a). 20 Respondent's Further Submissions (n 18) [8](b). 21 Ibid [13](d). 22 [2016] FWC 5539 [29]. 23 Ibid. -- 8 of 14 -- 9 [17] The Respondent submits that, having regard to the complexities outlined above, representation by external legal advocates with expertise in workplace-related matters and experience appearing would provide assistance to the Commission.24 [18] Further, it is submitted that the Respondents have been represented by an external law firm during the proceedings before the QHRC and, given their ongoing involvement throughout the complaint process, are well positioned to assist in the efficient management of the proceedings and to ensure that attention is directed to the key issues to be addressed at hearing.25 [19] Where leave is granted, the Respondents further submit that its legal representatives would assist the Commission to efficiently and effectively deal with the proceedings by: a) Addressing any perception of bias the Applicant may raise;26 b) Managing the Respondents' evidence and narrowing the issues in dispute;27 and c) Streamlining the proceedings before the Commission, thereby promoting efficiency and reducing the risk of procedural delays.28 Consideration – Efficiency (s 530(4)(a)) [20] Ms Ashton maintains that the matter is not so complex that it warrants the granting of leave for the Respondent to be legally represented. She characterises the core of the dispute as relating to her "dismissal from employment and the handling of [her] complaints," during the course of her employment, which she argues are issues "routinely considered by the Commission".29 [21] Ms Ashton further contends that she has diligently prepared her materials and that the involvement of external lawyers will merely "introduce additional layers of formality" and "prolong hearings".30 [22] I do not accept the Complainant's characterisation of the proceedings as routine or simple. Although I acknowledge the Complainant's submission that the Commission regularly deals with matters involving discrimination, the precise interplay between the facts and the law will differ in each matter. 24 Application for leave to be legally represented (n 3) [14]. 25 Respondent's Further Submissions (n 18) [13] (c). 26 Application for leave to be legally represented (n 3) [13](a). 27 Ibid [13] (b). 28 Respondent's Further Submissions (n 18) [8](b). 29 Complainant's Further Submissions (n 11) [3]. 30 Ibid [5]. -- 9 of 14 -- 10 [23] Ms Ashton's complaint includes allegations of direct discrimination on the grounds of sex, age, and actual or imputed impairment.31 I am not persuaded by the submission that the issues in dispute are not sufficiently complex to warrant legal representation. Such allegations expose the Respondents to potential adverse findings being made against them, together with any consequential relief sought by the Complainant. [24] The application of statutory tests regarding attributes, comparators, and the distinction between direct and indirect discrimination involves technical concepts where the assistance of legal representation is of significant benefit to the Commission. [25] Further, on the material currently before the Commission, it would seem these proceedings will likely involve the evidence of numerous persons, which will encompass examination and cross examination of the witnesses. In this respect, I am of the view that legal representation will assist the efficient management of this process. Factual Complexity [26] In Sillay, Davis J, President, referred to the observations of Vice President O'Connor in Dawson, where his Honour stated:32 ... (a) generally, the skills and expertise of legal practitioners will be a help rather than a hindrance; (b) legal representatives have a paramount duty to the Court; and (c) The presence of lawyers generally ensures that a case will be run more efficiently and focussed on the relevant issues. [27] The factual matrix is not limited to a single termination decision. As touched on earlier, the Respondents note the matter involves a "long history" and allegations against "a number of individual employees" including the Head of Human Resources.33 [28] As observed in State of Queensland (Queensland Health) v Hume,34 efficiency is concerned with timeliness and the effective use of resources. I accept the Respondents' submission that external representation will assist in "managing the Respondents" evidence and narrowing the issues in dispute'.35 31 Referral of a Matter filed 16 June 2025 (n 2). 32 [2024] ICQ 16 (n 7), [20]-[21] citing State of Queensland (Department of the Premier and Cabinet) v Dawson [2021] QIRC 118. 33 Respondent's Further Submissions (n 18) [13](a). 34 Hume (n 9). 35 Respondent's Further Submissions (n 18) [13](b). -- 10 of 14 -- 11 [29] The Respondents' argument that external counsel can mitigate "internal conflict" between the corporate entity and the individual respondent is also persuasive.36 This separation ensures that evidence is adduced clearly, without the challenges that might arise if internal staff were attempting to represent both the employer and their accused colleague. [30] Accordingly, I am satisfied the granting of leave to be legally represented would enable the proceedings to be dealt with more efficiently, having regard to the complexity of the matter.37 Consideration - Fairness (s 530(4)(c)) [31] Given that I have granted leave for the Respondents to be legally represented pursuant to s 530(4)(a) of the IR Act, it is not strictly necessary to consider the Respondents' application pursuant to s 530(4)(c) of the IR Act, however I have considered the issue below. [32] Section 530(4)(c) requires the Commission to consider whether it would be unfair to grant leave, having regard to fairness between the parties. [33] Ms Ashton submits that allowing the Respondents to be legally represented would cause significant unfairness and imbalance in the proceedings in circumstances where she is self-represented.38 Further, it is submitted that allowing the Respondents to be legally represented would diminish Ms Ashton's ability to effectively present her case.39 [34] As a person without the financial means to engage legal representatives, Ms Ashton contends that legal representation of the Respondents would "compromise the integrity and fairness of the proceedings".40 In summary, Ms Ashton maintains: a) it would create a power imbalance between the parties;41 b) she would be at a significant disadvantage in cross-examination, handling procedural arguments, understanding legal terminology, and responding to legal submissions;42 and c) it would significantly reduce her ability to present her case effectively and would result in procedural and emotional harm. This is in a context where Ms Ashton 36 Ibid [13](a). 37 Industrial Relations Act 2016 (Qld) s 530(4)(a). 38 Objection to application for leave to be legally represented (n 3) [1]. 39 Ibid [3]. 40 Ibid [5]. 41 Complainant's Further Submissions (n 11) [8]. 42 Ibid [9]. -- 11 of 14 -- 12 submits, she is still recovering from a psychological injury sustained in the workplace and 'the added burden of facing a legal team would intensify that harm".43 [35] The Respondents submit that they are entitled to put forward their best case in defending themselves in proceedings commenced by Ms Ashton.44 In circumstances where Ms Ashton has not engaged legal representation, the Respondents submit this is not itself evidence of unfairness.45 [36] Further, the Respondents maintain there would be no injustice to Ms Ashton should the Respondent be granted leave to be legally represented. In support of this submission, the Respondents rely on the decision in Wanninayake v State of Queensland (Department of Natural Resources and Mines) ('Wanninayake') regarding the lack of representation for one of the parties, namely:46 The fact that one party, either by choice or circumstances, is not represented by a lawyer is no reason to deny the other party of parties of legal representation, particularly in significant and potentially complex cases. … To the extent that a self-represented party considers it likely that they will be at some disadvantage in proceedings where the other party is, or parties are, represented by lawyers, the self-represented party should proceed on the basis that the Commission will attempt to ensure that the proceedings are conducted fairly within the time allotted for the hearing. [37] In reply, Ms Ashton distinguishes previous authorities like Wanninayake on the basis that the Respondent here is a religious employer, not the State.47 [38] The Respondents also refer to the Industrial Relations (Tribunals) Rules 2011 ('the Rules'), which impose an obligation to ensure fairness between the parties through effective courtroom management and adherence to the Rules. The Respondents submit that this has been recognised as mitigating any perceived unfairness arising from one party being legally represented while the other is not.48 43 Ibid [12]. 44 Respondent's Further Submissions (n 18) [10] (a). 45 Application for leave to be legally represented (n 3) [17]. 46 [2014] QIRC 079 ('Wanninayake') 6. 47 Complainant's Further Submissions (n 11) [10]. 48 Application for leave to be legally represented (n 3) (20) referencing Rolph v State of Queensland (Department of Energy and Public Works) [2024] QIRC 188 [53] and Hassan v Queensland (Queensland Fire and Emergency Services) [2024] QIRC 167. -- 12 of 14 -- 13 [39] Ms Ashton submits that granting leave would cause a "power imbalance" because she is a self-represented individual facing a "large, well-resourced institution".49 Ms Ashton argues she will be at a "significant disadvantage in cross-examination" and responding to legal submissions.50 Furthermore, she submits that the "stress and anxiety" of facing a legal team will intensify her psychological injury.51 [40] While I understand the Complainant's apprehension, her arguments do not persuade me to refuse leave. Disparity of Resources [41] As determined in Wanninayake, the fact that one party is unrepresented is not, of itself, a reason to deny the other party representation. Fairness in this context does not require that both parties have equal financial resources. It requires that the proceedings be conducted in a way that allows both sides to be heard. In this regard, the Commission has a duty to ensure the Complainant is not unfairly disadvantaged by her lack of legal training, regardless of who represents the Respondents. Mental Health [42] The Applicant submits that facing a legal team will harm her health. However, there is no medical evidence before me to support this specific contention. Conversely, the involvement of professional advocates often reduces the burden on a self-represented party by ensuring that correspondence is professional and issues are clearly defined.52 The Nature of the Respondent [43] Whether the Respondent is a State entity or a large private institution, they are entitled to defend serious allegations of discrimination efficiently. The Respondents have acknowledged their obligations to the administration of justice.53 Conclusion [44] I am satisfied that granting leave will enable these proceedings to be dealt with more efficiently due to the legal and factual complexities identified. I do not consider that granting leave will result in unfairness to the Complainant that cannot be managed by the Commission's standard procedures. [45] The discretion is enlivened and I exercise it in favour of the Respondents. 49 Complainant's Further Submissions (n 11) [8]. 50 Ibid [9]. 51 Ibid [12]. 52 Hume (n 9) [55]. 53 Respondent's Further Submissions (n 18) [13](b). -- 13 of 14 -- 14 [46] I order accordingly. Order 1. Leave is granted for the First Respondent and Second Respondent to be legally represented pursuant to s 530(1)(c) of the Industrial Relations Act 2016 (Qld). -- 14 of 14 --