2024-UNAT-1439-Corr.1

2024-UNAT-1439-Corr.1, Egor Ovcharenko

UNAT Held or UNDT Pronouncements

The Appeals Tribunal found that the proportional adjustment of workload standards for self-revision services was a matter that fell squarely within the Administration’s discretionary authority.  The Appeals Tribunal was satisfied that the Administration followed all proper procedures when taking and implementing the contested decision, and the UNDT properly determined that there was no requirement for staff management consultations at the departmental or office level in relation to a specific appealable administrative decision.

The Appeals Tribunal dismissed the appeal and affirmed Judgment No. UNDT/2023/006.

Decision Contested or Judgment Appealed

Mr. Ovcharenko, a Reviser at the P-4 Level in the Russian Translation Service, Documentation Division, Department for General Assembly and Conference Management, together with several other staff members of the Department, contested before the UNDT the “unilateral change in the individual workload standards for translation and self-revision” as decided by the Under Secretary-General of the Department.  

The UNDT dismissed the applications finding them irreceivable ratione materiae, and upon remand by the UNAT, issued Judgment No. UNDT/2023/006 dismissing the application in its entirety on the merits. The UNDT found that the increase of the workload standard for self-revision was a lawful exercise of the USG/DGACM’s discretionary authority.  

Mr. Ovcharenko filed an appeal.

Legal Principle(s)

Where an issue has been decided in a final judgment, such issue becomes res judicata. It cannot be litigated again before the Tribunals.  The principle of res judicata creates legal certainty and brings disputes already litigated to finality.

Contested decisions which are specific appealable administrative decisions, and which have a “tangible individual direct impact” for each affected staff member, constitute individual cases and therefore should not be normally subject to staff consultation. 

The reassignment of staff members’ functions comes within the broad discretion of the Organization to use its resources and personnel as it deems appropriate. 

The Administration has broad discretion to reorganize the operations and departments to meet changing needs and economic realities.

As a matter of law, an employment relationship creates mutual obligations between the employer and the employee. In this light, the principle governing the obligations of parties under an employment contract within the United Nations system is that of “shared responsibility”. This principle obliges the Administration and the staff member to take corresponding steps in the event of changes in the terms or conditions of the contract of employment. An employment contract of a staff member subject to the internal laws of the United Nations is not the same as a contract between private parties. An international organization necessarily has the power to restructure some or all of its departments or units.

Outcome
Appeal dismissed on merits

OAJ prepared this case law summary for informational purposes only. It is no official record and should not be relied upon as an authoritative interpretation of the Tribunals' rulings. For the authoritative texts, please refer to the judgment or order rendered by the respective Tribunal. The Tribunals are the only bodies competent to interpret their respective judgments, as provided under Article 12(3) of the UNDT Statute and Article 11(3) of the UNAT Statute. Any inaccuracies in the publication are the sole responsibility of OAJ, which should be contacted directly for any correction requests. To provide comments, don't hesitate to get in touch with OAJ at oaj@un.org.

The judgment summaries were generally prepared in English. They were translated into French and are being reviewed for accuracy of the translation.