Justice Zondo in  F & J Electrical CC v MEWUSA obo E Mashatola and Other (CCT 131/14) [2015] ZACC 3 ; [2015] 5 BLLR 453 ; (2015) ILJ 1189 (17 February 2015) at para 27.

A party may have an order of the Labour Court rescinded under section 165(a) if it is shown that the order was erroneously sought or granted in the absence of that party.  Whether the court grants a rescission application under this provision does not depend upon the applicant showing good or sufficient cause.  It is simply enough if the order was erroneously sought or granted in the absence of that party.