Gordon and Comcare (Compensation) [2020] AATA 352 (27 February 2020)
Division:GENERAL DIVISION
File Number: 2016/6081
Re:Michael Gordon
APPLICANT
AndComcare
RESPONDENT
DECISION
Tribunal:A G Melick AO SC, Deputy President
Date:27 February 2020
Place:Canberra
The decision under review is set aside and, in substitution, the respondent is liable to pay compensation to the applicant for “rotator cuff (capsule) sprain (right)” pursuant to s 14 of the Act.
............................................................
A G Melick AO SC, Deputy President
Catchwords
WORKER’S COMPENSATION – acute shoulder injuries – whether the applicant has suffered an ailment, or aggravation of an ailment – whether the ailment was contributed to, to a significant degree, by his employment – whether respondent liable under section 14 of the Safety, Rehabilitation and Compensation Act 1988 – decision under review set aside and substituted
Legislation
Safety, Rehabilitation and Compensation Act 1988
Safety, Rehabilitation and Compensation and Other Legislation Amendment Act 2007Cases
Brennan and Comcare (1994) 50 FCR 555
Comcare and Martin [2016] HCA 43
Dunkerley and Comcare [2014] AATA 381
Kavas and Comcare [2011] AATA 935
Kearns and Australian Capital Territory [2019] AATA 1631
Kooragang Cement Pty Ltd v Bates (1994) 35 NSWLR 452
Small and Comcare [2017] AATA 2383REASONS FOR DECISION
A G Melick AO SC, Deputy President
27 February 2020
INTRODUCTION
The applicant has been a member of the Australian Federal Police (AFP) since 1987 and has held a variety of postings and specialist training including the Police Tactical Group (PTG), Special Operations Team (SOT), Response and Security Tactical Response (SRSTR) and the Police Dive Team.
Many of his duties involved stresses and impacts upon his right shoulder which remained asymptomatic until he injured the shoulder in a non-work related rugby union match.
Shortly thereafter, on 8 June 2016, the applicant lodged a workers’ compensation claim in respect of torn tendons in his right shoulder rotator cuff and damage to his right arm bicep tendon.
ISSUES FOR DETERMINATION
(a)Has the applicant suffered a physical ailment or ailments such as to satisfy s 4(1) of the Safety, Rehabilitation and Compensation Act 1988 (the Act)?
(b)Were any physical ailments or, alternatively, aggravation of physical ailments suffered by the applicant contributed to, to a significant degree, by his employment such as to satisfy s 5B of the Act?
(c)Is the applicant entitled to compensation under s 14 of the Act?
There was discussion at the hearing as to the appropriate test to be applied bearing in mind the change following the assent of the Safety, Rehabilitation and Compensation and Other Legislation Amendment Act 2007. This amended s 5B which now requires a contribution to a significant degree rather than a material contribution. I consider the material contribution test to have a lower threshold and hence will be covered by the second issue set out above: s 5B(3) of the Act; see also Kearns and Australian Capital Territory [2019] AATA 1631.
Furthermore, there being no evidence suggesting otherwise, I find that no significant event occurred before 1989 and…
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- Gordon and Comcare (Compensation) [2020] AATA 352
- Case
- [2020] AATA 352
- Decision Date
CaseChat Overview and Summary
The primary legal issues before the Deputy President were whether Mr Gordon had suffered an ailment or an aggravation of an ailment, and if so, whether his employment had contributed to that ailment to a significant degree, thereby establishing Comcare's liability under section 14 of the *Safety, Rehabilitation and Compensation Act 1988*. The court was required to determine the causal connection between Mr Gordon's employment and his shoulder condition, considering both the recent sporting incident and his history of workplace injuries.
The Deputy President applied a common-sense evaluation of the causal chain, drawing on principles from *Kooragang Cement Pty Ltd v Bates* and *Small v Commonwealth*. The medical evidence, particularly the report from Dr Vrancic, indicated that the radiological findings were consistent with an acute-on-chronic injury resulting from cumulative repetitive work activities as an AFP officer, rather than solely from the sporting incident. Dr Vrancic noted that previous workplace incidents in 2012 involving his right shoulder had settled but were significant enough to warrant incident reports. The Deputy President concluded that the work-related condition had contributed in a material sense to the applicant's injury.
Accordingly, the Deputy President set aside the decision under review and substituted an order that Comcare was liable to pay compensation to Mr Gordon for "rotator cuff (capsule) sprain (right)" pursuant to section 14 of the Act.
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
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Legal Principle Established
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