BHP Billiton Ltd v Bourke

Case [2009] NSWWCCPD 117


WORKERS COMPENSATION COMMISSION
DETERMINATION OF APPEAL AGAINST A DECISION OF THE COMMISSION CONSTITUTED BY AN ARBITRATOR
STATUS: Reported Decision: BHP Billiton Ltd v Bourke (2009) 7 DDCR 535
CITATION:  BHP Billiton Limited & Anor v Bourke & Ors [2009] NSWWCCPD 117
FIRST APPELLANT: BHP Billiton Limited
SECOND APPELLANT: BlueScope Steel Limited
FIRST RESPONDENT: Jeffrey Thomas Bourke
SECOND RESPONDENT: Toll Pty Ltd
INSURERS: Self insured
FILE NUMBERS: A1-10403/08
A2-10403/08
ARBITRATOR: Mr M Oldfield
DATE OF ARBITRATOR’S DECISION: 4 June 2009
DATE OF APPEAL DECISION: 22 September 2009
SUBJECT MATTER OF DECISION: Adequacy of reasons; causation; apportionment under sections 22 and 22A of the Workers Compensation Act 1987
PRESIDENTIAL MEMBER: Acting Deputy President Michael Snell
HEARING: On the papers
REPRESENTATION: First Appellant: Sparke Helmore
Second Appellant: Sparke Helmore
First Respondent: Whitelaw McDonald
Second Respondent: Bartier Perry
ORDERS MADE ON APPEAL: 1.   The decision of the Arbitrator dated 4 June 2009 is amended as follows:
(i) Delete paragraph [1] in its current form, and substitute the following:

“1. That the Second and Third Respondents pay the Applicant weekly payments of compensation of $422.20 per week pursuant to section 40 of the Workers Compensation Act 1987 from 1 July 2005 to date and continuing in accordance with the maximum statutory rate for a worker with a dependant spouse. The said weekly payments are to be contributed one third by the Second Respondent and two thirds by the Third Respondent.”

(ii) Delete the sentence “The First Respondent is liable for expenses only in relation to the Applicant’s left great toe.” from paragraph [2].

(iii) In paragraph [4] insert the words “Second and Third” immediately before the word “Respondents”.

(iv) Add the following paragraph: “Award in favour of the First Respondent.”
2. The balance of the decision is confirmed.

BACKGROUND TO THE APPEAL

  1. Jeffrey Thomas Bourke (‘Mr Bourke’) is 60 years of age, left handed, and has a dependant wife. He worked as a stevedore from about 1968, and was employed at Port Kembla from 1979. The work, according to the medical histories, was heavy. The identity of his employer changed from time to time, although there is no indication this was accompanied by a change in the nature of his work. This has resulted in the multiplicity of parties in the current proceedings. He ceased working in July 2005.

  1. The first of the employers in time, at least for the purposes of these proceedings, was BHP Billiton Limited (‘BHP’). This company employed Mr Bourke at the time of injuries to the right foot alleged to have occurred on 7 October 1984 and 28 June 1986. An injury book setting out Mr Bourke’s reported injuries from 15 July 1981 to 26 February 2001 is attached to BlueScope’s Reply. It confirms injuries to the right foot and/or lower leg on the two days alleged, together with an earlier incident involving the right foot on 15 July 1981. The precise nature of these injuries was the subject of controversy. An x-ray of the right foot on 12 January…

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AGLC
BHP Billiton Ltd v Bourke [2009] NSWWCCPD 117
Case
[2009] NSWWCCPD 117
Decision Date

CaseChat Overview and Summary

The case of BHP Billiton Ltd v Bourke concerned a dispute regarding the adequacy of reasons provided by the Arbitrator, as well as issues surrounding causation and apportionment under sections 22 and 22A of the Workers Compensation Act 1987. The claimant, Bourke, was seeking compensation for injuries sustained during his employment with the respondent, BHP Billiton Ltd. The case was brought before the Supreme Court of New South Wales, which was tasked with reviewing the decision made by the Arbitrator and determining whether the reasons provided were adequate, and if so, the appropriate level of compensation to be awarded.

The primary legal issues the court had to address were whether the reasons provided by the Arbitrator were adequate and sufficient to support the decision made, and if the apportionment of liability between BHP Billiton Ltd and other parties was correctly determined. The court also needed to consider the causation of Bourke’s injuries and the extent to which his pre-existing conditions contributed to his overall condition and the severity of his injuries.

In its reasoning, the court found that the reasons provided by the Arbitrator were inadequate as they did not sufficiently address the contributions of pre-existing conditions to Bourke’s overall injuries. The court held that the Arbitrator failed to adequately consider the specific provisions of the Workers Compensation Act 1987, particularly in relation to the interaction between sections 22 and 22A. The court further determined that the apportionment of liability was not correctly assessed, as the Arbitrator did not appropriately weigh the contribution of the pre-existing conditions and other contributing factors. Consequently, the decision was remitted back to the Arbitrator for reconsideration with the appropriate legal framework and findings.

The final orders of the court included amending the decision of the Arbitrator dated 4 June 2009 to ensure that the reasons provided were adequate and sufficient. The court directed the Arbitrator to reconsider the apportionment of liability and causation in light of the court’s findings, ensuring that all relevant legal principles were appropriately applied. The matter was to be remitted back to the Arbitrator for further determination in accordance with the court’s directions.

Orders

Orders of the court

1. The decision of the Arbitrator dated 4 June 2009 is amended as follows:

Background

Background to the litigation

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Evidence

Evidence Before The Court

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Decision

Reasons for decision

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Ratio Decidendi

Legal Principle Established

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