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An HR consultant took necessary and appropriate steps to examine an employee's own conduct when determining whether her bullying and other allegations had a "proper foundation", the Federal Court has ruled.

This approach didn't refocus the investigation on the employee, nor alter her position to her detriment, Justice Craig Colvin found, in rejecting her $52 million adverse action claim.

The Court heard that in March 2019, the Department of Human Services employee sent a lengthy email to the people and culture team, describing various incidents of alleged bullying by a colleague.

She expressed frustration that the issues had been ongoing for about 12 months and were delaying her approval for overtime work and a promotion, but managers were "not able to get a handle of the ongoing negativity"...