In June 2026, the Supreme Court of Queensland delivered judgment in Hunter v Alliance Airlines [2026] QSC 140.
The case involved a workplace injury suffered by a flight attendant and cabin manager while performing pre-flight duties on an aircraft.
The decision is useful because it discusses manual handling, workplace systems, training, risk assessment, causation and the assessment of damages in a Queensland workplace injury matter.
This case note provides a general summary of the decision and some practical points that may be taken from it.
What Was the Case About?
The plaintiff, Ms Hunter, was employed by Alliance Airlines as a flight attendant and cabin manager.
She alleged that she injured her lower back while conducting a pre-flight security check of catering carts on an aircraft.
As part of the pre-flight process, catering carts needed to be moved from their stowed positions so that they could be checked. The incident occurred when Ms Hunter applied force to move a catering cart that was not moving freely from its docked position.
The injury was diagnosed as a back strain or musculoligamentous injury to the lumbar spine.
The Main Issue
The key issue was whether Alliance Airlines breached its duty of care to Ms Hunter.
There was no dispute that Alliance Airlines owed Ms Hunter a duty of care as her employer.
The dispute concerned whether Alliance had taken reasonable steps to protect against the risk of injury associated with moving catering carts from their stowed positions.
The Risk Identified by the Court
The Court considered the physical setup of the aircraft galley, the confined space, the way the catering carts were stowed, and the possibility that the carts could resist movement.
The Court found that the risk involved two related matters:
- A flight attendant may encounter significant resistance when trying to move a cart from its stowed position; and
- The flight attendant may respond by applying significant pulling force while positioned in a way that could cause musculoskeletal injury.
The Court considered that the risk was foreseeable and not insignificant.
Training and Systems of Work
A major part of the decision concerned the training and systems Alliance had in place.
The Court considered evidence about manuals, initial training, practical training, in-flight training, online manual handling material and on-board checking processes.
Although Alliance had general manual handling material, the Court found that the training did not sufficiently address the specific task of pulling a catering cart from its stowed position in the confined aircraft galley.
The Court also found that Alliance’s checking process did not amount to a system of monitoring whether flight attendants were using safe manual handling methods when performing that task.
What Precautions Did the Court Say Were Required?
The Court considered that reasonable precautions would have included:
- Training flight attendants to pull carts from a front-on position with the back in natural alignment;
- Using the full force of the body, including the legs;
- Seeking assistance from another flight attendant if significant resistance was encountered; and
- Maintaining a system of monitoring and review to ensure those things were being done.
The Court found that the burden of taking those precautions was low.
Causation
The Court accepted that Ms Hunter’s injury was caused by the application of significant force while pulling and twisting.
The Court found that, if Alliance had taken the required precautions, Ms Hunter was likely to have followed the training and system. On that basis, the breach of duty was found to be a necessary condition of the injury.
Alliance was held liable.
No Contributory Negligence
Alliance argued that Ms Hunter had contributed to her own injury.
The Court rejected that argument.
The Court noted that there was no evidence that Ms Hunter had ignored any specific training or instruction. Her response to the resistant cart was treated as a natural response in the circumstances, particularly in the absence of specific guidance from Alliance.
Damages
The Court awarded damages to Ms Hunter.
The judgment considered several categories of damages, including:
- General damages;
- Past economic loss;
- Interest on past economic loss;
- Past special damages;
- Interest on past special damages;
- Future economic loss; and
- Other relevant adjustments.
The Court ultimately entered judgment for the plaintiff in the amount of $602,068.02.
Why This Case Is Useful
This decision is a useful reminder that workplace injury cases often depend on the detail of the task being performed.
General safety training may not be enough where a specific task creates a foreseeable risk of injury.
The case also shows the importance of evidence about:
- The physical layout of the workplace;
- How the task was actually performed;
- Whether resistance or difficulty was foreseeable;
- What training was provided;
- Whether training addressed the specific task;
- Whether workers were monitored after training;
- Medical evidence about injury and capacity; and
- Employment evidence about past and future earning capacity.
Practical Takeaway
The key takeaway from the decision is that a workplace system may need to address the real conditions in which a task is performed.
Where a task involves force, awkward posture, confined space or repeated manual handling, the question may not simply be whether general training existed. The question may be whether the system properly addressed the specific risk involved in the task.
The information on this page is general in nature and does not constitute legal advice.