The forced resignation ruling that puts manager check-ins under the spotlight
When a check-in becomes a forced resignation claim, the Fair Work ruling on 5 March 2026 has a clear message.
Amy Doran was barely four months into her role as Manager in Training at The Jewellery Group Pty Limited when she walked out the door. She had started on 13 February 2025. By 9 June 2025, she had handed in her resignation. And by the time the Fair Work Commission finished with the matter, the case had raised serious questions about how managers conduct difficult conversations at work.
Ms Doran alleged she had been subjected to repeated workplace bullying and unreasonable treatment during her employment. In her submissions, she described being called into a meeting on 20 April 2025 without notice and without a support person, during which she said her performance was scrutinised in a manner she found hostile and intimidating.
Her resignation letter largely centred on a separate unplanned meeting held on 30 April 2025, with Narelle Madden, Head of Brand Mazuchellis, and two regional managers. Ms Doran said her concerns about onboarding and training were invalidated, that she was subjected to intense scrutiny, and that she left visibly distraught. She submitted that the experience had caused her psychological injury, stress, and anxiety, and that her health was being affected by remaining in the role. She also said she had raised her concerns with line management and human resources, but that nothing was done.
Christine Gray, a former employee of The Jewellery Group, gave evidence in support of Ms Doran. Ms Gray told the Commission she had witnessed Ms Doran's distress after the 30 April 2025 meeting, that senior management were aware of issues affecting her development, and that she believed Ms Madden had deliberately intimidated fellow employees.
By 8 June 2025, Ms Doran had put her resignation in writing. She served her one-week notice period and left on 13 June 2025. She then filed a general protections claim, arguing the company's conduct had forced her out.
The Jewellery Group held firm. The company argued that neither the April meeting — characterised by the Respondent as an informal check-in to see how Ms Doran was settling in — nor a separate store visit by Ms Madden, where uninducted new staff were found and Ms Madden assisted with the induction process, had the probable effect of forcing a resignation. Critically, it noted that Ms Doran had not raised her concerns with Head of Human Resources David Webber before resigning.
Commissioner Schneider, sitting in Perth, handed down the decision on 5 March 2026. The Commission accepted that Ms Doran "certainly did not feel supported and did not feel that the meeting was beneficial," but found the evidence fell short of what the law requires. The decision also noted that Ms Doran did not resign in the heat of the moment. The resignation letter had been prepared the day before it was submitted. As the Commission observed: "The line distinguishing conduct that leaves an employee no real choice but to resign from an employee resigning at their own initiative is a narrow one." There was no evidence of a formal performance management process being contemplated. The application was dismissed.
The Commission's reasoning points directly at two things HR teams control: how managers conduct welfare conversations, and whether employees trust the grievance channels available to them.
The case involved multiple concerning meeting dynamics across Ms Doran's short tenure, including an unplanned discussion with three senior managers and an earlier meeting she said was held without notice and without a support person. Whatever the intention behind each conversation, their cumulative effect on Ms Doran shaped the resignation that followed.
The fact that Ms Doran did not formally raise her concerns with HR before resigning was pivotal to the outcome. When employees bypass the channels in place, it is worth asking why.
