Goodricke v COMCARE (No.2)

In *Goodricke v COMCARE (No.2)*, the Administrative Appeals Tribunal (AAT) considered a dispute between Mr. Goodricke and COMCARE concerning Mr. Goodricke's claim for compensation under the *Safety, Rehabilitation and Compensation Act 1988* (Cth) (the SRC Act). Mr. Goodricke sought compensation for a psychological injury allegedly sustained during his employment with the Australian Federal Police.

The primary legal issue before the Tribunal was whether Mr. Goodricke's psychological condition constituted an "injury" as defined by section 5B of the SRC Act. Specifically, the Tribunal had to determine if the injury was suffered in the course of his employment and if the employment was the sole or dominant cause of the injury, or if it was contributed to by certain circumstances excluded by the Act, such as reasonable administrative action taken in a reasonable manner.

Judge Jarrett found that Mr. Goodricke's psychological condition was not an "injury" for the purposes of the SRC Act. The Tribunal applied the principles established in *Comcare v Martin* and *Comcare v Wood*, which require a causal link between the employment and the injury. The Tribunal concluded that while Mr. Goodricke had experienced difficulties and stress in his employment, these were not the sole or dominant cause of his psychological condition. Instead, the evidence indicated that the condition was primarily caused by personal circumstances unrelated to his employment, and any employment-related stressors were not sufficient to meet the threshold for an injury under the Act, particularly when considering the exclusion for reasonable administrative action.

The Tribunal affirmed the decision under review and dismissed Mr. Goodricke's application.