Peti and Comcare (Compensation)
[2016] AATA 50
•2 February 2016
Peti and Comcare (Compensation) [2016] AATA 50 (2 February 2016)
Division
GENERAL DIVISION
File Number(s)
2015/0358
Re
Maria Peti
APPLICANT
And
Comcare
RESPONDENT
DECISION
Tribunal Dr I Alexander, Member
Date 2 February 2016 Place Sydney The decision under review is affirmed.
........................[sgd]................................................
Dr I Alexander, Member
CATCHWORDS
WORKERS COMPENSATION – claim for pain in the left ear, tinnitus – whether applicant suffered an injury arising out of, or in the course of, the employee's employment - insufficient evidence of diagnosis or causal connection to employment – decision under review affirmed
LEGISLATION
Safety, Rehabilitation and Compensation Act 1988 ss 4, 5A, 5B, 14
SECONDARY MATERIALS
Department of Human Services Work Health and Safety Guidelines
REASONS FOR DECISION
Dr I Alexander, Member
2 February 2016
INTRODUCTION
Ms Peti commenced employment with the Department of Human Services (DHS) in December 2006. She was employed as a Customer Service Officer (CSO) in the Liverpool Multilingual Call Centre.
On 23 April 2014 Ms Peti lodged a claim for worker’s compensation, pursuant to s 14 of the Safety, Rehabilitation and Compensation Act 1988(Cth)(the SRC Act), in respect of a claimed injury described as “pain in the left ear, tinnitus”, which is said to have occurred on the 9 April 2014, when she was at work.
In a reviewable decision, dated 28 November 2014, a delegated review officer affirmed an earlier decision by Comcare to deny liability for Ms Peti’s claimed condition. The officer accepted that Ms Peti suffered an ailment, described as “tinnitus”, but decided that the available evidence did not support a conclusion that her employment had significantly contributed to her ailment so that she was not entitled to compensation under s 14 of the SRC Act.
In these proceedings Ms Peti seeks review of the reviewable decision of 28 November 2014 and seeks compensation for injury caused by her employment.
At the hearing Ms Peti was self-represented and the Respondent was represented by counsel.
ISSUES
Ms Peti submits that on 9 April 2014 while on the telephone at work she experienced an episode of acute pain and when the pain eventually resolved she became aware of noises in the left side of her head which has been described as “tinnitus in left ear”. She submits that the acute onset of the pain must have been caused by the telephone earpiece she was using at time and that this episode significantly contributed to the onset of her “tinnitus” and she is therefore entitled to compensation.
Compensation is payable pursuant to the provisions of s 14(1) of the SRC Act which reads as follows:
(1) Subject to this Part, Comcare is liable to pay compensation in accordance with this Act in respect of an injury suffered by an employee if the injury results in death, incapacity for work, or impairment
The definition of “injury” in s 5A of the SRC Act is as follows:
5A Definition of injury
(1) In this Act:
injury means:
(a) a disease suffered by an employee; or
(b) an injury (other than a disease) suffered by an employee, that is a physical or mental injury arising out of, or in the course of, the employee’s employment; or
(c) an aggravation of a physical or mental injury (other than a disease) suffered by an employee (whether or not that injury arose out of, or in the course of, the employee’s employment), that is an aggravation that arose out of, or in the course of, that employment;
but does not include a disease, injury or aggravation suffered as a result of reasonable administrative action taken in a reasonable manner in respect of the employee’s employment…
Therefore, the first issue the Tribunal must consider is whether on the 9 April 2014 Ms Peti suffered an injury arising out of or, in the course of, her employment.
For the purposes of the SRC Act the definition of “disease” in section 5B as follows:
5B Definition of disease
(1) In this Act:
“disease” means:
(a) an ailment suffered by an employee; or
(b) an aggravation of such an ailment;
that was contributed to, to a significant degree, by the employee’s employment by the Commonwealth or a licensee.
(2) In determining whether an ailment or aggravation was contributed to, to a significant degree, by an employee’s employment by the Commonwealth or a licensee, the following matters may be taken into account:
(a) the duration of the employment;
(b) the nature of, and particular tasks involved in, the employment;
(c) any predisposition of the employee to the ailment or aggravation;
(d) any activities of the employee not related to the employment;
(e) any other matters affecting the employee’s health.
This subsection does not limit the matters that may be taken into account.
(3) In this Act:
significant degree means a degree that is substantially more than material.
Section 4 of the SRC Act defines an “ailment” as “…any physical or mental ailment, disorder, defect or morbid condition (whether of sudden onset or gradual development)”.
It is agreed that Ms Peti suffers “left sided tinnitus” and that this symptom can be considered to be an “ailment” for the purposes of the Act.
Therefore the second issue the Tribunal must consider is whether Ms Peti’s ailment of “left sided tinnitus” was contributed to, to a significant degree, by her employment.
EVIDENCE
Ms Peti’s evidence
In an email dated 17 April 2014 Ms Peti states, inter alia, the following:
…LSO Craig came and have asked him if he has a new set of ear ph and he stated does not have those one like I had and only thing he has was head ph and he got me those…..too big for my head…tried to use but pain, pressure and strange feeling in my head and face travelling on my left side of neck and arm that had reported to my team leader ….[asked to] try other work station…once I put head ph on the pressure and pain was actually getting worse (also felling (sic) of vomiting nausea)…took ph off and try to do some of phone processing back on my work station…as time passes the pain and pressure and fullness in my head face etc has stayed have advised other t/l…that I am leaving and going to emergency… pain started to decrease took myself to emergency department to Campbelltown…seen by nurse…pain started to decrease in my face right cheek was the worst around12:30pm…doctor checked me around 13:00-13:30…when she checked my left ear with instrument the pain inside was unbearable…[at] around 4.00 pm same day 09/04 in my ears started buzzing, whistling noise very loud like having summer crickets in my head ….pain and pressure and fullness like something stuck in ear still persistent… sometimes less. Varies in places around my left ear, behind ear, whole left side, noise is most in left ear but sometimes in both…next day I went to see my doctor…..when he checked my left ear with the instrument there was no pain and there was no redness any more…
Ms Peti told the Tribunal that in 2008 she started “getting redness both ears” and that in 2009 she attended her GP because the “skin on the ear was cracking” and she had “pain in the earlobes and itchiness” but agreed that there had been no problem with her inner ear or hearing.
Ms Peti stated she always used the telephone earpiece on the right ear and never on the left ear. About six to seven weeks prior to the episode on 9 April 2014 she intermittently noticed “a little bit of sensation and pressure when I would be on a call” in the right ear. The sensation was very brief and was relieved by removing the earpiece.
When asked by the Tribunal to point to the location of the “sensation and pressure” she pointed to the skull behind the right ear and not to the ear itself.
Ms Peti described the episode as follows:
I had a customer and we were talking and suddenly was just immense pressure, like my head is going to explode. The back of the pain - the back of the head here was so sharp pain…it was just unbelievable and immediately pain went through my neck here and into my third finger.
Ms Peti described the pain as “awful…it was nagging, throbbing as - but it’s so hard to explain what it is and I thought it was electricity…never, ever experienced, it was just pressure, I thought just my head is going to explode and the pain was so immense I thought everything just going to explode” and added that she also began to feel nauseated but did not vomit.
Ms Peti demonstrated to the Tribunal that the pain started on the right side of her head and then went to the back of her head, to the left side of her face, to the left shoulder and down the left arm to the left ring finger. She explained that the right sided pain had “gone immediately” but the pain in the left side of her face persisted and had not subsided “not even a little bit” while she was driving to Campbelltown Hospital.
Ms Peti stated that she was still in severe pain at the hospital but was not given any analgesic medication. When examined by a doctor at about 1.30pm she experienced pain in the left ear when an otoscope was introduced into the left ear canal, but no pain when the right ear was examined.
Ms Peti stated that her pain eased during the afternoon and stopped overnight, but at about 4.30pm, while at home, she experienced a sudden onset of “noise” which she described as follows:
…oh my gosh, what is now. But it’s not in ear, it’s in head, that’s what I’m trying to explain it. Like I hear it on my left ear but it’s in my head, and sometimes what happens is this, it would - like if there’s a line between left and right, and then it’s on that line this is just the sound that it goes “bzzz” or whistle or whatever.
On the following day when Ms Peti attended her GP all the pain had resolved and his examination of both ears revealed no abnormality and caused no pain. However the left sided “noise”, now described as “tinnitus”, was still present.
In cross-examination, Ms Peti, when asked whether during the time between 8.30am(when she said the episode began) and the time when she was talking to the nurse at the hospital, her pain had changed in any way, she stated the following:
…pain it was same, it was immense pain. The only thing that I didn’t have, I didn’t have - in the finger I didn’t have nausea and I didn’t have it but that was just the initial - but it is, I didn’t have that. And I didn’t have a pressure in the ear, the big one. I had it just in the head, on the left side…
When asked about a note on the record that the triage nurse made, that she refused to have analgesia, Ms Peti said that was unable to remember anything about that.
Also during cross examination it was confirmed that Ms Peti had used an earpiece in her right ear for about six years and that she did not use one on the left ear.
MEDICAL EVIDENCE
Campbelltown Hospital
Emergency Department (ED) Clinical Records note the following:
Registration date/time – 09/04/2014 10:42
Triage Time – 10.48
Triage Comment – “PRESSURE IN L EAR. WORKS IN CALL CENTRE. ON PHONE ALL THE TIME. PAIN FOR MONTHS. SOME PAIN IN L FACE. PINS AND NEEDLES IN L FINGERS AND PAIN IN L CHEEK. PH OF LIMB PAIN AND INVESTIGATED. SOME NAUSEA TODAY. O/E NO FACIAL DROOP. = LIMB STRENGTH PEARL……..PT MOVING WEL LOOKS WELL
1105 hrs ivc ü Bloods ü Refused analgesia [emphasis added]
ED Discharge referral notes the following:
Discharge date/time – 09/04/2015 14:23
Admission summary - ….49 year old lady working in a call centre presented with 6 weeks history of pain in her ear and face on and off, while she is on the phone. No numbness or tingling….today it was severe and she felt it went down to her both side of face and left upper limb as well felt tinglish to her left finger region…she was able to drive from LPH to here with that…symptoms settled spontaneously…no headache or fever…no vomiting or photophobia [and] no other systemic symptoms. [emphasis added]
On examination …..looks well….left ear loss of light reflex to ear drum and mild redness…pupils ERTL…cranial nerves normal…..other vitals notes- stable. [emphasis added]
Plan – ….bloods unremarkable, she is already on Amoxicillin for infection D/C, MRI as OP and GP follow up
Dr Ghaly, General Practitioner
In a medical certificate dated 11 April 2014 Dr Gahly noted that Ms Peti “is suffering from unexplained pain under investigation…pain in the left ear, tinnitus”.
In a referral letter to Dr Greenberg dated 24 April 2014, Dr Ghaly stated the following:
Thank you for seeing Ms Maria Peti, age 49 years, for opinion and management….pain in the L ear ear, tinnitus, she has this problem for 5 years, getting worse[sic].
In a letter dated 5 June 2014 Dr Ghaly noted, inter alia, that Ms Peti
had history before this attack of felling [sic] pressure when using ear phone for couple of seconds for approximately 6 weeks…couple of days after the incident she started to feel itchy scalp for few days.
Dr Chang, ENT surgeon
In a letter dated 23 May 2011 Dr Chang noted that Ms Peti
is very anxious about the intermittent pain she feel in the left pinna and she also felt that the left pinna is larger than the right. Clinically I did not see any abnormality…I noted that she has acoustic dips at 6000 hertz in both ears but they very mild and just need to be monitored and checked from time to time.
In a letter dated 29 April 2014 Dr Chang stated, inter alia, the following :
Thank you for referring this lady who a few weeks ago experienced severe pressure and pain in the right ear while she was using a headphone in the call centre at Centrelink and this pain spread to the back of her head and her scalp was very itchy and then after that she felt the discomfort in her left ear and since that incident she felt that she has severe tinnitus. She also is feeling unusual itchiness in her left ear to the point that at night she scratches her ear and she has noticed a little bit of bleeding. The discomfort she feels in the left side of the ear also involved the left half of the face and down her left upper limb to her little finger…I am not sure what is happening here but clinically I did not discover any obvious abnormality on examining her ears…she had a preliminary hearing test today…which turned out to be within normal. [sic] She again mentioned that when they attempted to do the bone conduction test on her it was accompanied by severe pain behind here ear and at the back of her head. She claimed that the bone conductor that is placed on her mastoid region for the test precipitated these symptoms…I am baffled by the widespread symptoms that she is experiencing and it is quite obvious that she is very anxious about using the headphones at the call centre…I think she should also see a Neurologist… [emphasis added]
In a report dated 27 May 2014 Dr Chang noted a history of symptoms similar to that in his earlier letter and stated, inter alia, the following:
…The clinical examination of her ears did not reveal any visible abnormality in her outer ears and the eardrums. The middle ears were clear…her latest hearing test on 1 May 2014 showed essentially normal hearing with slight low tone air bone gap bilaterally and moderate high tone dip at 6khz bilaterally(R=L). I am unable to estimate a date when Ms Peti suffered her hearing impairment and I am also unable to indicate that the above mentioned changes in her hearing are associated with her current employment…The hearing loss is progressive and irreversible. The tinnitus may be episodic or become permanent…previous hearing tests carried out by other testers (on 29 November 2006 and 23 December 2010) also showed evidence of hearing losses bilaterally in the high frequencies at 6 khz…based on previous hearing test reports Ms Peti already suffered from high tone hearing losses dating back to 29 November 2006 at least…I am unable to specify that Ms Peti’s hearing loss is partly or wholly related to her employment with the Department of Human Services…the hearing losses are permanent …Ms Peti indicated that she suffers from tinnitus. Her high tone hearing losses may possibly be the cause of her tinnitus…I indicated to her that I am baffled by the wide spread nature of her symptoms. [emphasis added]
Other Medical letters and reports
In a letter dated 30 May 2014 Dr Griffith, neurologist, stated, inter alia, the following:
Thank you for asking me to see Maria Petri who is aware of an intermittent pain in her left ear which began about 5 years ago….she managed until on 9th of April this year at work she experienced a sudden exploding pain in her head mainly over the occipital regions extending into the left ear and left side of her neck. There was no pain in the left arm or forearm. She felt a sudden brief pain in the left ring finger…she then drove to Campbelltown Hospital emergency department. Her left finger pain resolved. She reports ongoing tinnitus in the left ear, consisting of a mixture of cricket like and beelike sounds, which is constant. Sometimes the whole head is affected by these sounds. She stated prior to the sudden left ear pain she would wear a headset at the call centre where she worked. She is no longer wearing a headset instead she is dealing with computers and desk work. She was adamant that there is no Workers Compensation Claim or solicitor involved in this matter….on examination today she was slightly anxious yet neurologically normal to physical examination…At this point Maria has unexplained left sided tinnitus…her cerebral MRI scan showed a few minor areas of increased signal intensity throughout the deep white matter consistent with age and previous smoking history…I could find no neurological abnormality…
In a report dated 14 August 2014 Associate Professor Krishnan, neurologist, noted that Ms Peti’s “current symptoms consist of dull pain which is most prominent over the left ear” and that at times she wakes with the pain.
Professor Krishnan stated on 9 April 2014 that Ms Peti also developed acute symptoms at work when taking a phone call. The symptoms were described as “very severe right-sided head pressure” which was accompanied by nausea and “dysaesthesia in her left 3rd digit”. She also reported “very significant tinnitus in the left ear…which began after the incident on 9 April 2014” but no symptoms on the right and dull pain over the left ear which is “never disabling”.
On physical examination Professor Krishnan noted no abnormal findings.
Professor Krishnan contacted Dr Chang who is reported to have said that an audiogram had demonstrated an “acoustic dip” at 6kHz which is consistent with noise related hearing damage but could not comment on whether this was due to Ms Peti’s current employment.
In a report dated 23 September 2014 Dr Dowe, consultant otolaryngologist, noted, inter alia, the following:
…She still has occasional pain in both ears but particularly on the left side and sometimes when lying on the ear the ear is painful too…in April 2014… she developed severe right -sided head pressure and pain…also… pain on the left side which radiated down to her arm…the pain and symptoms were so severe that she attended casualty where they could find nothing specifically wrong…shortly after she attended the emergency department and I gather at home she developed left tinnitus. This is still present and persistent. It seems to vary a lot in loudness. It is only in the left ear but sometimes she feels it all over her head… The initial symptoms were accompanied by severe headaches I gather these have now settled.
On clinical examination Dr Dowe noted that the ears and drums appeared normal.
In a letter dated 7 October 2014 Dr Siva locum to Macarthur ENT stated, inter alia, the following:
…She reports that it began on the day of the 9th of April, following a sudden sensation and pressure in the left ear, whilst she was using a headphone at work. There may have been a sudden burst of intense noise, although she cannot be sure of it…The left ear remained blocked and the sharp pain became a pressure like discomfort and subsequently spread to the left hemi-face and the occipital region. ..She denied neck pain, headaches or vestibular symptoms. She had also developed paresthesia of the left upper limb, down to little finger…she also described some itchiness in the ear, along with the blocked sensation, which had provoked her to scratch the ear canal and cause a bit of bleeding…This had settled…Since this event she is troubled by continuous high pitched tinnitus in the left ear. She is most affected by this in quiet environments. She is fortunately able to get to sleep with this…She denied ongoing left aural fullness, left hemi-facial or ear discomfort …clinical examination showed healthy ear canals, tympanic membranes and mobility of the drums…Vestibular, lower cranial nerve and cerebellar examinations were also normal. Neck, TMJ, Cspine and nasoendoscopic examination to the laryngohypopharynx were also unremarkable and exclude these sites as sources for referred pain to the ear…I am uncertain as to the aetiology of her sudden left aural symptoms” [emphasis added]
In a letter dated 18 March 2015 Dr Greenberg, Macarthur ENT, stated the following:
Thank you for referring Maria for review. She is having a tough time with her left ear…I had a very good look at this area today and I am satisfied nothing sinister is occurring…I do think that TMJ discomfort is one of the possibilities which could be considered and potentially referral to a maxillofacial surgeon is an option. I am happy with the appearance of the ear, rum however, and although it is frustrating, I cannot see a clear cause of her symptoms…Maria will have a CT scan of the temporal bone. This has not been done previously…
Audiometric Testing
Audiogram 29 November 2006 - normal with mild bilateral hearing loss (R>L) at 6kHz
Audiogram 23 December 2010- hearing is normal up to & including 3 kHz with a very mild high frequency hearing loss in both ears…Maria’s primary concern is not hearing instead it is pain in her left ear. This issue would best be assessed by an ear, nose and throat specialist.
Audiogram 12 November 2012 – hearing normal up to 6000 Hz, she shows a very mild high frequency hearing loss in both the left & right ears…Maria is still reporting pain in her left ear. As previously advised, this concern is best assessed by an ear nose, and throat specialist.
Audiogram 1 May 2014 – essentially normal hearing with moderate high tone dip at 6kHz bilaterally (R=L)
Auditory brainstem response analysis 1 May 2014 – normal auditory evoked responses bilaterally
Audiogram – 9 September 2014 – essentially the same as her pre-employment audiogram
Audiogram 18 March 2015 – mild high frequency hearing loss right and left – continuous tinnitus and constant pain reported in the left ear
Radiological studies
A MRI brain scan dated 15 April 2014 stated:
Clinical indication: Unexplained pain in head with nausea, looking for intracranial pathology
Conclusion: Non-specific supratentorial white matter changes……no other intracranial abnormality…
I note no mention of “tinnitus”.
CT petrous bones 30 March 2015:
Clinical history – ongoing left ear pain? Cause
Conclusion - no significant acute pathology or structural bony abnormality seen in relation to the petrous temporal bones on either side
Incident reports
The incident reports on the following dates noted the following:
27/02/2009 – irritation inflammation of skin on the right ear lobe
12/11/2010 – have problem with ears system/hearing for some time…
14/03/2011– have pain in LEFT ear, whole ear system and ear lobe…
20/09/2011 – redness, dry skin, pain, irritation, inflammation of skin on left ear lobe
4/03/2014– INTIMIDATION, HARRASSENT AND DISCRIMINATION…WHOLE BODY, HEADACHE, NOT SLEEPING…
9/04/2014:
-Time of incident: 08:30
-Time reported: 08:50
- Incident - “PRESSURE IN EARS AND HEAD, HEADACHE, STRANGE SENSATION IN HEAD FACE NECK …” had strange sensation and pressure going through my side of head and across and through my chain and face and neck front and back when on call with cus by self or cus and interpreter, sometimes is so bad had to take headset off, will see doctor today, this had started approx 6 weeks ago but is not always some day no issues with ph and some days is from morning…[sic]
Other Evidence
Ms Peti provided the Tribunal with two large bundles of copies of emails and other documents most of which were already in the three volumes of section 37 documents. Most of the material in the bundles was not directly relevant to the specific issues before the Tribunal.
There are several documents in the bundles concerned with various technical issues with respect to the telephone equipment used by Ms Peti. However, there is no evidence that her phone equipment was faulty.
CONSIDERATION
The issue as to whether Ms Peti suffered an “injury” arising out of, or in the course of, her employment is somewhat problematic.
I accept that she suffered symptoms while at work, however, there is no clearly identifiable incident which caused her symptoms, there is no explanation for her symptoms, there is no evidence of physiological change and the symptoms resolved spontaneously within a relatively short time without any treatment.
Furthermore, the precise nature and severity of the symptoms on the day in question is, in my view, unclear.
The accounts of the episode on 9 April 2014 provided to the various health care professionals and the Tribunal are somewhat inconsistent, particularly with regard to the location and severity of the symptoms. In my view, this raises concerns about some retrospective embellishment.
There is evidence to suggest that Ms Peti has suffered pain in relation to left ear for several years with no apparent explanation as to the cause of the pain.
Ms Peti at various times has described her symptoms during the relevant episode as “pain was unbearable…sudden exploding pain…very severe…so severe…immense pressure…head is going to explode…pain was so immense.”
Nevertheless she was able to drive herself to Campbelltown Hospital, a journey that took more than one hour. The triage nurse noted that she “looked well” and refused “analgesia”. The doctor who examined her noted that “symptoms had settled spontaneously…no headache…looks well…is already on Amoxicllin for infection” and allowed her to be discharged home after less than four hours of observation.
I note there is no other evidence before the Tribunal with respect to the nature of the “infection” that was being treated.
At the hearing the question as to whether on the 9 April 2014 Ms Peti suffered an “acoustic incident” was raised.
In the Department of Human Services Work Health and Safety Guidelines (the Guide) an “acoustic incident” is defined as “a sudden, unexpected loud sound of non-speech character experienced by a head set user. There may be crackles, hisses whistles, shrieks or high pitched noises”.
There is no evidence that Ms Peti suffered an “acoustic incident” on 9 April 2014. At no time has she described the occurrence of a “sudden unexpected loud sound” as outlined in the Guide.
Furthermore, at the time of the episode Ms Peti was wearing an earphone on her right ear and she has described her symptoms as being predominantly on the left side of her face and associated with the left ear.
Accordingly, I am satisfied that on 9 April 2014 Ms Peti did not suffer an “acoustic incident” or an injury arising out of, or in the course of her employment within the meaning of s 14 of the SRC Act.
I accept that Ms Peti suffers from persistent “left sided tinnitus” and that this symptom, which appears to have arisen at home on the 9 April 2014 following the episode at work, is difficult to treat and clearly causes her significant distress.
The cause of the left sided “tinnitus” remains unexplained despite assessments by several medical specialists and the relationship between the onset of the symptom and her employment is unclear. The only abnormality found on investigation is the persistent mild to moderate high frequency hearing loss in both ears which was already present in 2006 at the time of her initial employment.
Furthermore, in her own evidence she conceded that she has not used a telephone earpiece on the left ear for more than six years.
Apart from a temporal relationship and Ms Peti’s own assertions there is, in fact, no evidence before the Tribunal that supports a conclusion that there was any contribution to her symptom of “tinnitus” by her employment.
Dr Chang speculates that the “tinnitus” may be related to the long standing high frequency hearing loss. Dr Greenberg speculates that “temporomandibular joint discomfort” may be contributing to her symptoms, a condition that has not been fully investigated.
Accordingly, I am satisfied that there is insufficient evidence before the Tribunal to support a conclusion that Ms Peti’s ailment, “left sided tinnitus”, was contributed to, to a significant degree, by her employment so that she is not entitled to compensation pursuant to s 14 of the SRC Act.
DECISION
For reasons set out above I am satisfied that Comcare is not liable to pay compensation pursuant to s 14 of the SRC Act.
The decision under review is affirmed.
I certify that the preceding 69 (sixty-nine) paragraphs are a true copy of the reasons for the decision herein of Dr I Alexander, Member
...........................[sgd].............................................
Associate
Dated 2 February 2016
Date(s) of hearing 17 December 2015 Applicant In person Counsel for the Respondent R Henderson Solicitors for the Respondent Lehmann Snell Lawyers
Key Legal Topics
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Employment Law
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Statutory Interpretation
Legal Concepts
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Causation
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