NEW SOUTH WALES COURT OF APPEAL
CITATION: DARKE v EL DEBAL; EL DEBAL v NETWORK WELDING PTY LTD (IN LIQ) ;EL DEBAL v KARI & GHOSSAYN PTY LTD [2006] NSWCA 86
FILE NUMBER(S):
40013/2005
40186/2005
40272/2005
HEARING DATE(S): 27, 28 March 2006
DECISION DATE: 21/04/2006
PARTIES:
Michelle DARKE v Khaled EL DEBAL
Khaled EL DEBAL v NETWORK WELDING PTY LTD (in liq)
Khaled EL DEBAL v KARI & GHOSSAYN PTY LTD
JUDGMENT OF: Mason P Santow JA McColl JA
LOWER COURT JURISDICTION: District Court
LOWER COURT FILE NUMBER(S): DC 3576/2002
LOWER COURT JUDICIAL OFFICER: Christie ADCJ
COUNSEL:
Darke: A Robertson SC/ D J Cutler
El Debal: R S McIlwaine SC/ D R J Toomey
Network: H Halligan
Kari: R R Bartlett SC/ S Finnane
Abigroup: S A Kerr
SOLICITORS:
Darke: Ferguson Lawyers
El Debal: Carroll & O'Dea
Network: Edwards Michael
Kari: Hunt & Hunt
Abigroup: Wotton & Kearney
CATCHWORDS:
APPEAL AND NEW TRIAL – Improper admission or rejection of evidence – Failure to consider all relevant evidence – Decided points not put by counsel – Failure to address all pleaded causes of action – Failure to give reasons.
NEGLIGENCE – Employer’s duty of care – Duty to provide safe system of work – Where employer typically hires out the services of its employees – Employer to acquaint itself with the system of work in the place to which its sends its employees.
NEGLIGENCE – Construction safety – Requirement that any person who directly or by their servants or agents carries out construction work owes a duty of care – May be more than one person owing duty – Head contractor and subcontractor jointly liable – Construction Safety Regulations 1950, regs 73 and 80.
NEGLIGENCE – Motor vehicle accidents – Damages – Non-economic loss – Recoverable only where degree of permanent impairment actually greater than ten per cent – Whether recoverable if degree of permanent impairment potentially greater than 10 per cent – Medical assessor’s certificate under motor accidents compensation legislation – Provides conclusive evidence as to whether degree of permanent impairment greater than 10 per cent – Whether evidence as to potential degree of permanent impairment certifiable – Motor Accidents Compensation Act 1999, s 61(2)(a).
NEGLIGENCE – Motor vehicle accidents – Damages – Non-economic loss – Medical assessor’s certificate under motor accidents compensation legislation – Provides conclusive evidence as to matters certified regarding degree of permanent impairment – Rejection where certificate not made in circumstances affording procedural fairness to a party – Where certifying doctor fails to consider plaintiff’s description of injuries – Procedural fairness concerned with process not outcomes – No basis for rejecting certificate established – Motor Accidents Compensation Act 1999, s 61(4).(D)
LEGISLATION CITED:
Construction Safety Regulations regs 73 and 80
Law Reform (Miscellaneous Provisions) Act 1946
Motor Accidents Compensation Act 1999
Workers Compensation Act 1987, s151N
DECISION:
New trial as to some issues
JUDGMENT:
IN THE SUPREME COURT
OF NEW SOUTH WALES
COURT OF APPEAL
CA 40013/2005
CA 40186/2005
CA 40272/200
DC 3576/2002MASON P
SANTOW…
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- AGLC
- Darke v El Debal [2006] NSWCA 86
- Case
- [2006] NSWCA 86
- Decision Date
CaseChat Overview and Summary
The primary legal issues before the Court of Appeal were whether the trial judge had improperly admitted or rejected evidence, failed to consider all relevant evidence, decided points not put by counsel, failed to address all pleaded causes of action, and failed to give adequate reasons for the decision. Specifically, the court had to determine the scope of an employer's duty of care when hiring out employees, the application of construction safety regulations, and the conclusive nature of a medical assessor's certificate regarding permanent impairment for the purposes of non-economic loss claims under the *Motor Accidents Compensation Act 1999*.
The Court of Appeal found that the trial judge had erred in several respects, including failing to adequately consider the evidence and address all pleaded causes of action. The court also considered the admissibility of the medical assessor's certificate, noting that while such certificates are generally conclusive regarding the degree of permanent impairment, they can be rejected if not made with procedural fairness. However, the court found no basis to reject the certificate in this instance, as the procedural fairness concerns related to the process rather than the outcome.
Ultimately, the Court of Appeal ordered a new trial on some of the issues in the case, acknowledging that the original trial had not been conducted in a manner that allowed for a just determination of all matters in dispute.
Orders
Orders of the court
New trial as to some issues
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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