SUPREME COURT OF SOUTH AUSTRALIA
(Full Court: Civil)
BRENNAN-LIM v RETURN TO WORK SA
[2017] SASCFC 105
Judgment of The Full Court
(The Honourable Justice Parker, The Honourable Justice Lovell and The Honourable Justice Hinton)
18 August 2017
WORKERS' COMPENSATION - ASSESSMENT AND AMOUNT OF COMPENSATION - AMOUNT OF COMPENSATION DURING INCAPACITY - LUMP SUM PAYMENTS - SPECIFIC INJURIES - LIMB INJURIES
WORKERS' COMPENSATION - ASSESSMENT AND AMOUNT OF COMPENSATION - AMOUNT OF COMPENSATION DURING INCAPACITY - LUMP SUM PAYMENTS - PERMANENT IMPAIRMENT AND LOSS
WORKERS' COMPENSATION - PROCEEDINGS TO OBTAIN COMPENSATION - DETERMINATION OF CLAIMS - PROCEDURE - GENERALLY
WORKERS' COMPENSATION - PROCEEDINGS TO OBTAIN COMPENSATION - DETERMINATION OF CLAIMS - EVIDENCE - MEDICAL EVIDENCE
Appeal against a decision of the Full Bench of the Workers Compensation Tribunal.
The appellant sustained injuries when she suffered a fall during the course of her employment. In October 2011, the appellant underwent surgery for a total knee replacement of her right knee. In 2013, the appellant claimed lump sum compensation for non-economic loss arising from her injuries. The claims agent obtained a medical report from Dr Dobson. Dr Dobson assessed the appellant as having suffered a 15% whole person impairment (WPI) due to her right knee replacement. The appellant accepted the determination to award her $29,231 as compensation.
In March 2015, the appellant lodged an application with the Workers Compensation Tribunal disputing Dr Dobson’s previous 15% WPI assessment. Dr Dobson provided a revised WPI assessment of 20% for the appellant’s right knee impairment and 1% for scarring. The appellant relied on the evidence of two occupational physicians, Dr D’Onise and Dr Suyapto, who both assessed WPI at 32%. The Deputy President accepted Dr Dobson’s revised assessment and awarded lump sum compensation of $45,551. The appellant unsuccessfully appealed the Deputy President’s decision to the Full Bench of the Workers Compensation Tribunal on a question of law.
The appellant now appeals to this Court on three grounds:
1. That the Deputy President provided inadequate reasons to support his finding that the appellant was mistaken when she testified her knee pain was constant, rather than intermittent;
2. That the appellant was denied procedural fairness because she was not given an opportunity in her evidence to comment on the proposition that she was mistaken; and
3. That the Deputy President and the Full Bench erred in their construction of Table 17.35 of the WorkCover Guidelines for the evaluation of permanent impairment and section 43A(8)(b) of the Workers Rehabilitation and Compensation Act 1986 (SA) (Act).
Held per Parker J (Lovell and Hinton JJ agreeing), dismissing the appeal:
1. The appellant’s evidence that there had been no deterioration since 2013, combined with the evidence of all three assessors about fluctuations on the day of assessment supported the Deputy President’s conclusion that the appellant’s knee pain was intermittent, rather than constant (at [92]-[94]).The Deputy President’s reasons satisfy each of the requirements referred to in RESI Corporation v Munzer [2016] SASCFC 15 and were adequate (at [95]);
2. The appellant…
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- Brennan-Lim v Return to Work SA [2017] SASCFC 105
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- [2017] SASCFC 105
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CaseChat Overview and Summary
The appeal raised three questions of law. Firstly, whether the Deputy President's reasons for concluding that the appellant had mistakenly testified about her knee pain being constant or intermittent were legally adequate. Secondly, whether the finding of mistaken testimony regarding constant pain was procedurally unfair, as the appellant was not given an opportunity to comment on the proposition that she was honest but mistaken. Thirdly, whether the Deputy President and the Full Bench erred in their interpretation of Table 17.35 of the WorkCover Guidelines for the evaluation of permanent impairment and section 43A(8)(b) of the *Workers Rehabilitation and Compensation Act 1986* (SA).
The Court considered the appellant's evidence, which included statements about experiencing "constant levels of mid-level to high-level pain" in her right knee, though she also acknowledged that the "very bad pain isn't there all the time" and that pain levels fluctuated depending on her activities. The Deputy President had relied on the assessment of Dr Peter Dobson, who had noted the pain as "intermittent" in his report, leading to a 20% WPI. The appellant contended that a higher WPI was warranted. The Court found that the Deputy President's reasons for preferring Dr Dobson's assessment, particularly regarding the interpretation of "intermittent" pain, were adequate in the context of the forensic contest. The Court also determined that the appellant had not been denied procedural fairness, as the issue of mistaken testimony was explored during cross-examination and the appellant had the opportunity to respond. Furthermore, the Court found no error in the construction of the relevant guidelines and legislation.
Consequently, the Full Court dismissed the appeal on all three grounds. The parties were to be heard as to costs.
Orders
Orders of the court
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Background
Background to the litigation
Evidence
Evidence Before The Court
Decision
Reasons for decision
Ratio Decidendi
Legal Principle Established
Before considering the three grounds of appeal I will make some observations about the operation of the points system under Table 17.35 and the effect of the allocated points on the assessment of WPI.Operation of the points system The underlying issue in this appeal is whether the appellant’s WPI arising from her right knee impairment was properly assessed at 20% WPI or 30% WPI. The Deputy President adopted Dr Dobson’s assessment of 76 points and thus a WPI of 20%. In order to be assessed at 30% WPI the appellant needed to accrue less than 50 points under Table 17.35. In that context it is appropriate to summarise the points rating applied to the appellant by the three assessors under Table 17.35. As there is no challenge in this appeal to the finding by the Deputy President that points should not be deducted for extension lag, that measurement has been excluded from the summary. The variation in points rating caused by differences in the findings made about mediolateral and anterioposterior stability, and to a lesser extent range of motion, must be considered in light of the evidence given by all three medical assessors that these objective measurements may vary depending upon how the person felt on the day of the examination. The rating given for pain is not based upon the situation on the day of examination but rather the description given by the person about their overall level of pain and the assessor’s interpretation of that information. The significance of the allocation of points for the assessment of pain is illustrated by the following examples. If the pain rating of 30 points ultimately adopted by Dr Dobson were to replace the 10 points allocated by each of Dr D’Onise and Dr Suyapto, their aggregate points rating would respectively be 52 points and 61 points. On the other hand, if the rating of 10 points for pain allocated by both Dr D’Onise and Dr Suyapto were to be combined with the rating for each of the several objective measurements given by Dr Dobson, the result would be an allocation of 56 points.[2] [2] There would be 10 points for pain, 23 points for range of motion, 10 points in respect of anterioposterior stability and 15 points for mediolateral stability with 2 points being deducted for flexion contracture. The result is that the appellant could only achieve a rating below 50 points and thus a 30% WPI assessment if the Deputy President were to be found to have erred by preferring the evidence of Dr Dobson to that of the other two assessors in respect of both the assessment of pain and the objective measurements. Ground 1 - inadequate reasons The principles to be applied when determining whether or not a judge has provided adequate reasons were summarised by Kirby P (as his Honour then was) in Soulemezis v Dudley (Holdings) Pty Ltd as follows:[3] This decision does not require of trial judges a tedious examination of detailed evidence or a minute explanation of every step in the reasoning process that leads to the judge’s conclusion. But the judicial obligation to give reasons and not to frustrate the legislative facility of appeal on questions of law, at least obliges a judge to state generally and briefly the grounds which have led him or her to the conclusion reached concerning disputed factual questions and to list the findings on the principle contested issue. Only if this is done can this court to discharge its functions, if an appeal is brought to it.[3] (1987) 10 NSWLR 247 at 259.