[2014] AATA 117
Division VETERANS' APPEALS DIVISION File Number
2013/3935
Re
Jan Fotek
APPLICANT
And
Repatriation Commission
RESPONDENT
DECISION
Tribunal Mr R G Kenny, Senior Member
Date 5 March 2014 Place Brisbane The Tribunal affirms the decision under review.
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Mr R G Kenny, Senior Member
CATCHWORDS
VETERANS’ AFFAIRS – Disability pension – Operational service with Royal Australian Navy – Application of Statement of Principles – Appropriate diagnosis of psychiatric conditions – No factual basis for diagnosis of posttraumatic stress disorder – Posttraumatic stress disorder not war-caused – Decision under review affirmed
LEGISLATION
Veterans’ Entitlements Act 1986 (Cth) ss 6C, 7, 9, 14, 37, 120, 120A, 196B
CASES
Fogarty v Repatriation Commission [2003] FCAFC 136; (2003) 37 AAR 363
O’Dowd v Repatriation Commission [2013] FCA 991
Repatriation Commission v Bawden (2012) 206 FCR 296
Repatriation Commission v Cornelius [2002] FCA 750
Repatriation Commission v Warren (2007) 95 ALD 606
SECONDARY MATERIALS
Statement of Principles concerning Posttraumatic Stress Disorder, No. 5 of 2008 (As amended by Amendment Statement of Principles no 19 of 2014).
REASONS FOR DECISION
Mr R G Kenny, Senior Member
5 March 2014
BACKGROUND
On 5 August 2010, Jan Fotek lodged with the Repatriation Commission
(“the respondent”), in accordance with s 14 of the Veterans’ Entitlements Act 1986 (Cth) (“the Act”), a claim for a disability pension in respect of a condition diagnosed as posttraumatic stress disorder. He contended that this was related to circumstances of his service with the Royal Australian Navy (“the RAN”) while he was serving in South Vietnam. On 14 December 2010, the respondent determined that Mr Fotek’s posttraumatic stress disorder was not related to his service. On 21 May 2013, the Veterans’ Review Board affirmed the decision.
ISSUES AND SERVICE
Mr Fotek served in the RAN from 3 January 1967 until 8 July 1988 and this included a period of eligible war service in the form of operational service, as provided for in s 7 and s 6C of the Act, respectively, from 14 September 1970 until 8 April 1971. He also served a period of defence service which is not relevant to this claim. Under s 9(1)(b) of the Act, a condition will be war-caused if it “arose out of, or was attributable to, any eligible war service rendered by the veteran”.
The standard of proof to be used in determining diagnostic matters under the Act is provided for in s 120(4). This requires that such matters be determined on the balance of probabilities.[1] For issues of causation for operational service, the standard of proof is set out in s 120(1) of the Act. It reads:
Where a claim under Part II for a pension in respect of the incapacity from injury or disease of a veteran, or of the death of a veteran, relates to the operational service rendered by the veteran, the Commission shall determine that the injury was a war caused injury, that the disease was a war-caused disease or that the death of the veteran…
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CaseChat Overview and Summary
The court examined the evidence provided by both parties. Mr Fotek claimed that three specific incidents during his service in South Vietnam met the diagnostic criteria for PTSD. The respondent, however, argued that the evidence did not support a PTSD diagnosis and, even if it did, the condition was not attributable to Mr Fotek’s operational service as required by the Act. The court considered the credibility and factual basis of Mr Fotek’s claims regarding these incidents and whether they indeed caused the alleged PTSD.
After reviewing the evidence, the court concluded that there was no factual basis for a diagnosis of PTSD based on the incidents described by Mr Fotek. The court found that even if PTSD were diagnosed, it could not be attributed to his operational service as none of the incidents occurred as claimed. The court affirmed the decision under review, upholding the Commission’s decision to deny Mr Fotek's claim for a disability pension related to PTSD.
The court's decision was grounded in the lack of evidentiary support for both the diagnosis and the attribution of PTSD to Mr Fotek’s service, as required by the Act. The evidence did not substantiate the claimed incidents or their effects on Mr Fotek, leading the court to affirm the decision to reject his pension claim.
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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