The Labour Court found it had no jurisdiction to hear a worker’s bullying claim against Securitas Security Services because a Rights Commissioner had already heard it. The recommendation was dated 27 February 2012; the merits were not decided. The worker had referred the case under section 20(1) of the Industrial Relations Act 1969 rather than appealing the earlier recommendation. The Court said section 13(10) barred it from investigating a trade dispute already heard by a Rights Commissioner, except on appeal.