Cash and Australian Postal Corporation (Compensation)

This matter concerned an application by Ms Cash against the Australian Postal Corporation regarding compensation for injuries sustained during her employment. The dispute centred on whether Ms Cash continued to suffer from a compensable psychiatric condition and whether her ongoing physical ailments were still causally linked to her employment. The decision was made by Dr I Alexander, Senior Member, of the Tribunal.

The legal issues before the Tribunal were whether Ms Cash suffered a psychiatric condition that was contributed to, to a significant degree, by her employment, and whether the effects of her physical injuries, specifically bilateral plantar fasciitis and chronic regional pain syndrome (CRPS), had ceased. The Tribunal was required to determine if Ms Cash was entitled to ongoing compensation under sections 16 and 19 of the *Safety, Rehabilitation and Compensation Act 1988* (Cth) (SRC Act) as at 8 September 2016 and continuing to the present.

The Tribunal reasoned that while Ms Cash had suffered CRPS in her left lower limb triggered by plantar fasciitis, the precise nature of her current ailment was uncertain. Applying the principles from *Woodhouse v Comcare* [2021] FCAFC 95, the Tribunal held that the critical inquiry was whether the ailment continued to be contributed to, in a material degree, by the employee's employment. It was irrelevant whether the current ailment was characterised as the same or a different ailment from the original injury. The Tribunal found that Comcare's liability ceases if the ailment no longer has the necessary causal connection to the employee's employment, even if the ailment itself continues unabated.

The Tribunal affirmed the decisions under review, indicating that Ms Cash was not found to be entitled to ongoing compensation for the psychiatric condition or to have established the necessary continuing causal link between her current physical ailments and her employment.