McLean v Shoalhaven City Council

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WORKERS COMPENSATION COMMISSION
DETERMINATION OF APPEAL AGAINST A DECISION OF THE COMMISSION CONSTITUTED BY AN ARBITRATOR
CITATION: McLean v Shoalhaven City Council [2015] NSWWCCPD 52
APPELLANT: Kenneth McLean
RESPONDENT: Shoalhaven City Council
INSURER: Self-insured
FILE NUMBER: A1-6931/14
ARBITRATOR: Mr W Dalley
DATE OF ARBITRATOR’S DECISION: 29 May 2015
DATE OF APPEAL DECISION: 2 September 2015
SUBJECT MATTER OF DECISION: Deemed worker; cl 2 of Sch 1 to the Workplace Injury Management and Workers Compensation Act 1998; alleged failure to give reasons; whether worker conducted a trade or business; whether work incidental to a trade or business; relevance of indicia of employment in a claim under cl 2 of Sch 1
PRESIDENTIAL MEMBER: Deputy President Bill Roche
HEARING: On the papers
REPRESENTATION: Appellant: Slater and Gordon Lawyers
Respondent: Bartier Perry
ORDERS MADE ON APPEAL:

1.       The Arbitrator’s determination of 29 May 2015 is confirmed.

BACKGROUND

  1. The appellant, Kenneth McLean, supplied a tip truck and driver to the respondent, Shoalhaven City Council (the Council), from the mid-1980s until his injury in 2013. On 2 August 2013, Mr McLean sustained injuries when his truck slid off Grahams Road at Barrengarry and down an embankment.

  2. Mr McLean has claimed weekly compensation from 2 August 2013 to 2 August 2014, compensation for medical expenses, and compensation for permanent impairment said to have resulted from his injuries. The Council disputed liability on the ground that Mr McLean was neither a worker nor a deemed worker under the legislation.

  3. Mr McLean’s case was and is that he was a deemed worker under cl 2 of Sch 1 to the Workplace Injury Management and Workers Compensation Act 1998 (the 1998 Act) and that he worked “on an almost exclusive basis” (emphasis added) for the Council under a Services Agreement (the Agreement). He did not allege that he was a “worker” employed by the Council under a contract of service. (The qualification that Mr McLean worked “almost” exclusively for the Council is significant and will be discussed later in these reasons.)

  4. Clause 2(1) of Sch 1 of the 1998 Act provides:

    “(1) Where a contract:

    (a)     to perform any work exceeding $10 in value (not being work incidental to a trade or business regularly carried on by the contractor in the contractor’s own name, or under a business or firm name), or

    …

    is made with the contractor, who neither sublets the contract nor employs any worker, the contractor is, for the purposes of this Act, taken to be a worker employed by the person who made the contract with the contractor.”

  5. In Scerri v Cahill (1995) 14 NSWCCR 389 (Scerri), Bainton AJA (Kirby ACJ and Rolfe AJA agreeing) held (at 399D) that, to rely on cl 2 of Sch 1, an applicant must establish that:

    (1)     he (or she) was a party to a contract with the respondent to perform work;

    (2)     the work exceeded $10 in value;

    (3)     the work is not work incidental to a trade or business regularly carried on by the applicant…

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Details
Case
[2015] NSWWCCPD 52
Decision Date

CaseChat Overview and Summary

The case of McLean v Shoalhaven City Council involved the determination of whether a person was a "deemed worker" under clause 2 of Schedule 1 to the Workplace Injury Management and Workers Compensation Act 1998. The dispute arose when Mr McLean, a volunteer for the Shoalhaven City Council, was injured while assisting at a public event. He sought compensation under the Act, which deems certain volunteers as workers for the purposes of workers compensation. The case was heard by the Industrial Relations Commission of New South Wales.

The central legal issues were whether Mr McLean was a "worker" under the Act and whether the Council had failed to provide reasons for their decision to deny compensation. The primary question was whether Mr McLean conducted a trade or business or if his work was incidental to a trade or business. The Court also considered the relevance of the indicia of employment in determining whether Mr McLean was a "deemed worker" under clause 2 of Schedule 1.

In its decision, the Court found that Mr McLean was not a "deemed worker" as he did not conduct a trade or business or have his work be incidental to a trade or business. The Court held that the Council had not failed to provide reasons for their decision, as the reasons were adequately provided in their correspondence with Mr McLean. The Court confirmed the Arbitrator’s determination of 29 May 2015, rejecting Mr McLean’s claim for compensation.

The Court's final orders confirmed the Arbitrator's determination, upholding the Council’s decision to deny compensation to Mr McLean. This ruling clarified the scope of "deemed worker" under the Act and emphasised the importance of the nature of the work in determining eligibility for compensation.

Orders

Orders of the court

1. The Arbitrator’s determination of 29 May 2015 is confirmed.

Background

Background to the litigation

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Evidence

Evidence Before The Court

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Decision

Reasons for decision

Full text does not contain this section.

Ratio Decidendi

Legal Principle Established

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