Farrow-Smith and Comcare (Compensation) [2022] AATA 3157 (26 September 2022)
Division:GENERAL DIVISION
File Number: 2021/0312
Re:Elloise Farrow-Smith
APPLICANT
AndComcare
RESPONDENT
Decision
Tribunal:Deputy President J Sosso and Member L Benjamin
Date:26 September 2022
Place:Brisbane
The decision under review is affirmed.
.....................[SGD].................................
Deputy President J Sosso
Catchwords
COMPENSATION – Ross River Virus – self-reporting of symptoms – conflicting medical opinion – credibility of witnesses – ailment was not contributed to, to a significant degree, by her employment – decision under review affirmed
Legislation
Safety, Rehabilitation and Compensation Act 1988 (Cth)
Cases
Adelaide Stevedoring Company Limited v Forst (1940) 64 CLR 538
Amaca Pty Ltd v Ellis (2010) 240 CLR 111
D’Amico and Comcare [2018] AATA 54
Davis v Council of the City of Wagga Wagga [2004] NSWCA 34
E.M.I (Australia) v Bes (1970) 44 WCR 114
Military Rehabilitation and Compensation Commission v May (2016) 257 CLR 468
Tully and Comcare [1996] AAT 349
White and Military Rehabilitation and Compensation Commission [2017] AATA 1555
Secondary Materials
Farmer, JF, Suhrbier A, ‘Interpreting paired serology for Ross River virus and Barmah Forest virus’, AJGP Vol 48, September 2019.
Flexman, JP, et al, ‘A comparison of the diseases caused by Ross River virus and Barmah Forest virus’ (1998) 169 MJA 159.
Harley et al, ‘Ross River Virus Transmission: Infection and Disease: a Cross-Disciplinary Review’, Clinical Microbiology Reviews, Oct 2001
Lucas, RE, Qiao, M, ‘A case of encephalitis in central Australia due to Ross River virus?’ Aust NZ J Med 1999, Vol 29, 25 March 2008.
New South Wales Government, ‘NSW Arbovirus Surveillance & Mosquito Monitoring 2019 – 2020’, Weekly Update: 14 February 2020 (Report Number 8).
REASONS FOR DECISION
Deputy President J Sosso and Member L Benjamin
26 September 2022
INTRODUCTION
Ms Elloise Farrow-Smith (the Applicant) seeks review of a decision dated 11 December 2020 by a Review Officer of Comcare which affirmed a determination of 9 September 2020 declining liability to pay compensation for the contraction of Ross River Virus, pursuant to s 14 of the Safety, Rehabilitation and Compensation Act 1988 (Cth) (the Act) – Exhibit 1 T19 pp. 167 – 172.
The Applicant was born in 1969 and moved to the Northern Rivers District of New South Wales in 1974. Apart from periods during which she undertook study or work duties, the Applicant has been a resident of this region since 1974 – Exhibit 4 para 5.
The Applicant has resided at Suffolk Park, which is in the Byron Bay locality, since 2002 – Exhibit 4 para 21.
The Applicant commenced working with the Australian Broadcasting Corporation (ABC) as a journalist in June 1999. At all relevant times, the Applicant was employed as a journalist with the ABC – Exhibit 1 T7 p. 30, Exhibit 2 para 2.5.
On 12, 13 and 14 February 2020, the Applicant was assigned to cover floods which were affecting the Tweed,…
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- AGLC
- Farrow-Smith and Comcare (Compensation) [2022] AATA 3157
- Case
- [2022] AATA 3157
- Decision Date
CaseChat Overview and Summary
The court was required to determine whether the applicant had suffered an ailment and, if so, whether that ailment was contributed to, to a significant degree, by her employment. This involved assessing the credibility of the applicant's testimony regarding the severity and duration of her symptoms, particularly in light of conflicting medical opinions and contemporaneous medical records.
Deputy President Sosso P acknowledged that disease and injury are not mutually exclusive concepts, referencing established High Court authority. The court found that the evidence presented supported the conclusion that the applicant had suffered an ailment as a result of mosquito bites. However, after considering the testimony of the applicant, her partner, and medical professionals, and critically examining the applicant's account against the available medical records, the court concluded that the applicant's ailment was not contributed to, to a significant degree, by her employment.
Consequently, the decision under review was affirmed.
Orders
Orders of the court
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Background
Background to the litigation
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Evidence
Evidence Before The Court
Decision
Reasons for decision
Ratio Decidendi
Legal Principle Established
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