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Although a workplace had "clear" interpersonal conflict issues, an employer didn't facilitate a toxic environment that forced a manager to resign, the Fair Work Commission has found.

Deputy President Nicholas Lake noted that constructive dismissal cases involved a "high bar"; it wasn't enough just to prove a toxic workplace prompted a resignation.

"There must be action by the employer, that, when viewed objectively, left the [manager] with no choice but to resign," he said...