Meeuwissen v. Hilton Hotels of Australia Pty Ltd.

In a prior judgment, the Commission found that Hilton Hotels of Australia had discriminated against Sue Meeuwissen and Neil Francey under section 103(1)(b)(i) of the Disability Discrimination Act by permitting smoking in their premises (a nightclub), causing the complainants difficulty breathing in such an environment. Ms Meeuwissen had cystic fibrosis - her doctor had recommended that she live in a smoke-free environment. In the earlier judgment, the Commission had ordered that the respondent pay the complainants damages, but had requested written submissions on possible declarations that it could make for preventing further discrimination under section 103(1)(b). (See: Francey v Hilton Hotels of Australia Pty Ltd [1997] HREOCA 56.)

The Commission concluded that all but one of the options available to it were not viable (separation of smokers and non-smokers; separate smoking and non-smoking environments within the venue; and the use of ventilation-filtration systems). Only a complete ban on smoking in entertainment venues would prevent further discrimination towards disabled non-smokers. However, the Commission declined to make such a declaration on the basis that momentum was building to ban smoking in public entertainment venues, and it was inappropriate to single out this venue for an earlier ban.

Meeuwissen v Hilton Hotels of Australia, Nos. H97/50 & H97/51, Human Rights and Equal Opportunity Commission (2000).

  • Australia
  • Mar 10, 2000
  • Human Rights and Equal Opportunity Commission

Parties

Plaintiff

  • Neil Francey
  • Sue Meeuwissen

Defendant Hilton Hotels of Australia

Legislation Cited

Disability Discrimination Act 1992 (NSW)

Smoking Regulation Act 1997 (NSW)

Related Documents

Type of Litigation

Tobacco Control Topics

Substantive Issues

Type of Tobacco Product

None

"4.4.4 Prohibition of Smoking at the Venue: As indicated earlier, this was the option most favoured by submissions in support of the complainant. It has the merit of simplicity. Many submissions also argued that it would be of benefit to both patrons and staff of the nightclub as a whole, but this is not a matter for my consideration. It was argued in some submissions that a compromise could be to have certain non-smoking nights. But this is not viable for a number of reasons. It would be impossible for the respondent to determine on which nights non-smokers would be more likely to attend and smokers less. Whichever nights were chosen some people, on both sides of the issue, would be dissatisfied. Further, from the complainant's own submissions, the residual environmental tobacco smoke in furniture, curtains and carpets would require thorough cleaning to remove it. It would not be viable for the respondent to do this one or several times a week. The respondents again argued that to make the venue a non-smoking venue would make it non-viable as a business proposition. I am not so persuaded by this argument, as the evidence for the contention appears to be much more tenuous, and based on assumption and "gut-feeling". Evidence was brought by both sides on the viability and non-viability of smoke-free venues, but it was inconclusive. The question of the venue’s ongoing viability is not, in itself, persuasive. Whilst this decision does not relate to the general community debate over the efficacy of environmental tobacco smoke I cannot make the decision in a vacuum. Many public entertainment venues (although not nightclubs) are already smokefree. Several State governments have legislated to ban smoking in restaurants, hotels, clubs etc. In NSW, where the respondents venue is situated, legislation was passed by Parliament in 1997 which provides that smoking will not be allowed in public entertainment venues which do not comply with clean air standards five years after these standards have been introduced. However, no such standards have been promulgated. It is clear that momentum is building to ban smoking in public entertainment venues. In this context it seems to me inappropriate to single this venue out for an earlier ban because a complaint has been successfully brought under the Disability Discrimination Act. For this reason, I am not prepared to support this option."