Paxton and Repatriation Commission (Veterans' entitlements) [2019] AATA 1305 (17 June 2019)
Division:VETERANS' APPEALS DIVISION
File Number(s): 2016/3476
Re:Richard Paxton
APPLICANT
AndRepatriation Commission
RESPONDENT
DECISION
Tribunal:Senior Member Linda Kirk
Date:17 June 2019
Place:Sydney
The decision under review is affirmed.
...............................[SGD].........................................
Senior Member Linda Kirk
CATCHWORDS
VETERANS’ AFFAIRS — Veterans’ entitlements — Special rate of pension - Intermediate rate of pension— Whether Applicant's incapacity renders him incapable of undertaking remunerative work for period aggregating more than eight or 20 hours a week - Whether incapacity from war-caused injuries “alone” prevented the veteran from undertaking remunerative work — Whether the veteran genuinely sought to engage in remunerative work - Applicant incapable of undertaking remunerative work for periods aggregating more than eight hours - Applicant had no further work opportunities, suffers from non-service related conditions - Applicant fails 'alone' test - No evidence to show that Applicant sought to genuinely seek alternative remunerative work - reviewable decision affirmed
LEGISLATION
Veterans’ Entitlement Act 1986 (Cth)
CASES
Chambers v Repatriation Commission [1995] FCA 1144
Flentjar v Repatriation Commission [1997] FCA 1200
Forbes v Repatriation Commission [2000] FCA 328
Leane v Repatriation Commission [2004] FCAFC 83
Re Cavell and Repatriation Commission (1986) 10 ALN N233
Repatriation Commission v Buckingham [1996] FCA 1218
Repatriation Commission v Butcher [2007] FCAFC 36
Repatriation Commission v Hendy [2002] FCAFC 424
Repatriation Commission v Richmond [2014] FCAFC 124
Repatriation Commission v Watkins [2015] FCAFC 10
Smith v Repatriation Commission [2014] FCAFC 53
Starcevich v Repatriation Commission [1987] FCA 342Summers v Repatriation Commission [2015] FCAFC 36
SECONDARY MATERIALS
Robin Creyke and Peter Sutherland, Veterans’ Entitlements and Military Compensation Law
Guide to the Assessment of Rates of Veteran’s Pensions
REASONS FOR DECISION
Senior Member Linda Kirk
17 June 2019
INTRODUCTION
Mr Richard Paxton (‘the Applicant’) was born in 1949. He was conscripted into the Australian Army for National Service from 1 October 1969 to 31 December 1971. He rendered operational service for the purposes of the Veterans’ Entitlement Act 1986 (Cth) (‘the Act’) from 2 December 1970 to 18 November 1971.
On 9 July 2013 the Applicant lodged a claim for ‘Back’ stating it was related to ‘heavy lifting in Vietnam as storeman’.[1]
By Determination dated 30 October 2013, the Repatriation Commission (‘the Respondent’) accepted liability for lumbar spondylosis pursuant to the Act, with effect from 9 April 2013. The Determination increased disability pension to 40% of the General Rate.[2] This was an overall assessment that included incapacity for a previously accepted war-caused condition of bilateral sensorineural hearing loss.
On 11 November 2013 the Applicant lodged an application for review of the Determination dated 30 October 2013 to the Veterans’ Review Board (‘VRB’).[3]
On 12 December 2013 the VRB set aside an earlier decision of the Respondent dated 29 May 2012 and accepted liability for a claim made by the Applicant on 24 October 2011 for PTSD, alcohol dependence, irritable bowel syndrome, gastro-oesophageal reflux disease, lichen simplex chronicus and depressive disorder.
In a decision…
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- Case
- [2019] AATA 1305
- Decision Date
CaseChat Overview and Summary
The primary legal issues before the Tribunal were whether the applicant's incapacity from service-caused conditions, of itself alone, rendered him incapable of undertaking remunerative work for more than eight hours per week, and whether this incapacity alone prevented him from continuing his earlier remunerative work. The Tribunal also had to consider whether the applicant had genuinely sought alternative remunerative work and whether his war-related conditions were the substantial reason for his inability to work.
The Tribunal applied the principles established in *Smith v Repatriation Commission*, which outline a composite test for eligibility under sections 24(1)(b) and (c) of the relevant Act. This test requires that the war-related incapacity alone renders the veteran incapable of working more than eight hours per week, and that this incapacity alone prevents them from continuing earlier remunerative work, causing a loss of earnings. The Tribunal found that while the applicant was incapacitated, the evidence did not demonstrate that his service-caused conditions were the sole or substantial reason for his inability to work more than eight hours per week or to continue his previous employment. Furthermore, the Tribunal noted a lack of evidence that the applicant had genuinely sought alternative remunerative work.
Consequently, the Tribunal concluded that the applicant did not meet the criteria for payment of a pension at the special or intermediate rate. 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
The ameliorating provision does not apply in the Applicant’s circumstances because he has not been genuinely seeking alternative remunerative employment. Further, it does not apply because the evidence does not point to the accepted conditions being a substantial reason for the Applicant’s inability to work.CONSIDERATION AND REASONS The Tribunal has considered all of the material before it, as well as the oral submissions of the parties, the evidence of the Applicant and the expert medical evidence. The Tribunal is satisfied that the parties have had an adequate opportunity to present their case and to be heard by the Tribunal. The legislation requires that the evidence before the Tribunal must satisfy a number of tests; if any one of the criteria is not met, the Applicant will not be eligible for payment of pension at the Special or Intermediate Rate. There is no discretion in this regard. In Smith v Repatriation Commission [2014] FCAFC 53; (2014) FCR 452 (‘Smith’), Buchanan J elaborated at [47] – [49] upon the legislative requirements under s 24(1)(b) and (c) of the Act:Section 24(1)(b) and (c), when read together, state a composite test containing a series of conditions. First, s 24(1)(b) requires that a veteran be rendered, by the war-related incapacity alone, incapable of working more than eight hours per week. Secondly, s 24(1)(c) requires that the veteran be prevented, by that incapacity alone (i.e. not for other reasons) from continuing earlier remunerative work. Thirdly, s 24(1)(c) requires that prevention for that reason from continuing that work be the cause of a loss of earnings. Fourthly, s 24(1)(c) requires that the loss of earnings would not be suffered but for the incapacity.The operation of s 24(1)(c) is capable of being informed by the provisions of s 24(2). The overall effect of s 24(1)(c) may be summarised as one which requires a demonstrated loss of earnings as the direct result of the war-related incapacity, and only for that reason. Section 24(2)(a) supplements the requirements of s 24(1)(c) by identifying specific circumstances which will cause it not to be satisfied. Those circumstances, in effect, state the opposite to the conditions in s 24(1)(c) itself. Thus, there is no established loss of earnings by reason of the incapacity if remunerative work was ceased for other reasons (s 24(2)(a)(i)), or if the veteran is also incapacitated or prevented from doing remunerative work for some other reason (s 24(2)(a)(ii)). In this assessment, of course, it continues to be accepted that the veteran is actually incapacitated in any event (‘a veteran who isincapacitated...’). The purpose of the enquiry is to see whether, nevertheless, there are other explanations for economic loss so that the incapacity is not the only reason for it.(1) Does the Applicant’s incapacity from service-caused conditions of itself alone render him incapable of incapable of undertaking remunerative work? For a person aged under 65, s 24(1)(b) and s 23(1)(b) of the Act require that the Applicant's incapacity from service-caused conditions, must be of such a nature as, of itself alone, to render him incapable of undertaking remunerative work for more than 8 hours per week (or 20 hours a week, or, 50% of what is ordinarily worked in a particular kind of work for the Intermediate Rate).