| IN THE SUPREME COURT OF VICTORIA | Not Restricted |
AT MELBOURNE
COMMON LAW DIVISION
JUDICIAL REVIEW AND APPEALS LIST
S ECI 2021 04294
| FELICE SCARDAMAGLIA | Plaintiff |
| v | |
| AMCOR PTY LTD | First Defendant |
| - and - | |
| A/PROF BERNARD LYONS | Second Defendant |
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JUDGE: | FORBES J |
WHERE HELD: | Melbourne |
DATE OF HEARING: | 2 December 2022 |
DATE OF JUDGMENT: | 15 March 2023 |
CASE MAY BE CITED AS: | Scardamaglia v Amcor Pty Ltd & Anor |
MEDIUM NEUTRAL CITATION: | [2023] VSC 114 |
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ADMINISTRATIVE LAW — Judicial Review — Medical Panel — Impairment benefit claim—Industrial deafness — Diminution of hearing — Binaural percentage loss of hearing — Whether Panel erred in failing to consider the effect of tinnitus — Whether AMA Guides Chapter 9 applicable — Application of the Improved Procedure for Determining Percentage Loss of Hearing (NAL Procedure) — Relevance of the Guidelines published by the Australian Society of Otolaryngology, Head and Neck Surgery Victorian Section (ASOHNS Guidelines) — Minister’s approval dated 28 October 2018 of manner for determining the percentage of diminution of hearing — Accident Compensation Act 1985 ss 91(1), (3), (4).
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APPEARANCES: | Counsel | Solicitors |
| For the Plaintiff | J P Brett KC E Makowski | Williams Winter |
| For the First Defendant | R Kumar | Hall & Wilcox |
| For the Second Defendant | No appearance | Victorian Government Solicitor |
HER HONOUR:
Mr Scardamaglia (the plaintiff) has made a claim for an impairment benefit for industrial deafness. His claim was accepted and, having disputed the resulting 0% assessment of whole person impairment (WPI), the dispute was referred to a medical panel. The second defendant, who alone comprised the Medical Panel (the Panel), provided an opinion and accompanying reasons dated 18 September 2021 (the Panel Opinion and Reasons). The Panel concluded that the WPI was 0%. The plaintiff now seeks orders quashing the Opinion and remitting the questions to a differently constituted medical panel.
The plaintiff’s employer (the defendant) is the only defendant to contest the proceeding. The second defendant will abide by the outcome of the decision in accordance with a Hardiman letter dated 1 December 2021.[1]
Although the plaintiff’s claim form was dated 9 June 2020, and lodged during the operation of the Workplace Injury Rehabilitation and CompensationAct2013 (Vic), his last day of employment was 25 May 2012 and his injury was deemed to have been sustained on that day.[2] Accordingly his claim has been dealt with pursuant to the provisions of the Accident Compensation Act1985 (Vic) (the Act).
[2]Workplace Injury Rehabilitation and Compensation Act2013 (Vic) s 60(1).
The plaintiff relies on a single ground: that the Panel did not assess his industrial deafness in accordance with s 91 of the Act. The assessment was said to be erroneous because it failed to account for the presence of tinnitus. This was an alleged error of law described in a number of alternate ways: the Panel misunderstood its task…
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- Case
- [2023] VSC 114
- Decision Date
CaseChat Overview and Summary
The primary legal issues before the Tribunal were whether the medical panel erred by failing to consider the effect of tinnitus on the claimant's hearing, whether the Australian Medical Association Guides Chapter 9 was applicable in this context, and the relevance of the Guidelines published by the Australian Society of Otolaryngology, Head and Neck Surgery Victorian Section (ASOHNS Guidelines). Additionally, the Tribunal had to consider the Minister's approval dated 28 October 2018, which outlined the method for determining the percentage of diminution of hearing, and whether this approval aligned with the legislative provisions under sections 91(1), (3), and (4) of the Act.
The Tribunal found that the medical panel did not adequately consider the effect of tinnitus in determining the percentage loss of hearing. It held that the panel should have applied the NAL Procedure and taken into account the ASOHNS Guidelines. The Tribunal also noted that the Minister's approval did not conflict with the legislative requirements and was consistent with the statutory framework. Consequently, the Tribunal quashed the decision of the medical panel and remitted the matter for reconsideration in light of its findings.
The final orders of the Tribunal included the quashing of the decision of the medical panel and the direction that the matter be reconsidered by the panel, with specific instructions to consider the impact of tinnitus and to apply the NAL Procedure and the ASOHNS Guidelines in determining the percentage loss of hearing. The Tribunal also noted that the Minister's approval was in line with the legislative provisions and did not warrant further review.
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Evidence
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Decision
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