With great sadness the President acknowledges that former judge of the Commission and the first woman appointed to a superior court in NSW, the Hon Leone Carmel Glynn, passed away on 5 October 2026, aged 94.
Ms Glynn was called to the bar in 1964, and later appointed Librarian-in-Chief of the Supreme Court of NSW and the Industrial Relations Commission of NSW libraries.
In 1975, Ms Glynn was appointed a Conciliation Commissioner of the Commission, becoming the first woman to be appointed to the office of Commissioner.
In 1980, Ms Glynn was appointed a judge of the Commission, becoming the first woman in NSW, and one of the first women in Australia, to be appointed as a judge of a superior court of record.
While Ms Glynn determined many types of cases while on the bench of the Commission, she will be remembered for her important work in the Pay Equity Inquiry during 1997 and 1998. Her report in the Pay Equity Inquiry was a pioneering step forward for gender equity and equal remuneration in Australia.
By her report in the Pay Equity Inquiry, she rejected—contrary to the tests in force in the federal industrial system at that time—the notion that an equal remuneration claim requires the existence of actual discrimination, or proof of a causal connection between existing remuneration and some gendered circumstance, or proof of undervaluation by comparison with a male workforce. Instead, her report concluded that the only requirement, to be determined by reference to various indicia, is that remuneration should be “fixed irrespective of the sex of the worker so that there is equal remuneration for work of equal or comparable value”.
Ms Glynn’s groundbreaking report is now widely recognised as the model approach to rectifying gender undervaluation across Australia. It led to the adoption of a new equal remuneration wage fixing principle in NSW ensuring that the Commission—in every exercise of its power—provides equal remuneration for work of equal and comparable value, and ensuring that female workers are properly valued and remunerated. This principle has been applied to grant pay increases to librarians, child care workers, school assistants and, more recently, nurses throughout the state.
Through this work, Ms Glynn was at the centre of the development of the modern approach to rectifying gender undervaluation; an approach which commenced in NSW and which has been adopted and become universal across all Australian industrial jurisdictions in the rectification of gender undervaluation.
On her retirement from the Commission, then President, the Hon Justice Wright, remarked that “her Honour was known for her compassion, attention to detail and dedication to the proper performance of her office”.
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