Read and Military Rehabilitation and Compensation Commission (Compensation)

This matter came before the Administrative Appeals Tribunal concerning a claim for compensation by Mr Read against the Military Rehabilitation and Compensation Commission. The dispute centred on whether Mr Read was entitled to compensation for an adjustment disorder with anxious mood, which he contended arose from witnessing the immediate aftermath of an electrocution incident during his service in 1968. The Tribunal was required to determine if a diagnosis of late-onset Post-Traumatic Stress Disorder (PTSD) could be validly made and if Mr Read's ailment developed as a result of the service-related incident.

The Tribunal considered the expert evidence of two psychiatrists. Dr Likely attributed Mr Read's impairment points to an adjustment disorder arising directly from service-related traumas in 1968 and 2004. Dr Beaney, a psychiatrist with specialist training, provided evidence suggesting Mr Read had been experiencing difficulties since the age of 63, describing a need to maintain a "tough façade" which he could no longer sustain. She noted his description of ongoing symptoms, including poor sleep, flashbacks, irritability, and anger, which he believed stemmed from the 1968 incident.

The Tribunal acknowledged that late-onset PTSD can be a valid clinical diagnosis, noting that there is no arbitrary time limit for its manifestation. However, it also recognised that the longer the delay between a traumatic event and the diagnosis, the more difficult it is to establish a significant causal link, particularly if other traumatic events have occurred in the interim. Crucially, the Tribunal found that while the full impact of PTSD might develop over time, a person suffering from the condition will typically manifest symptoms from the onset of the original traumatic event. Based on the material presented, the Tribunal concluded that PTSD was not the correct diagnosis as not all criteria under DSM-5 were met, and therefore, the causative threshold for compensation could not be achieved. The decision under review was affirmed.