Sharp and Repatriation Commission (Veterans’ entitlements) [2016] AATA 719 (16 September 2016)
Division
VETERANS' APPEALS DIVISION
File Number(s)
2015/3842
Re
Brian Sharp
APPLICANT
And
Repatriation Commission
RESPONDENT
DECISION
Tribunal Ms N Isenberg, Senior Member
Date 16 September 2016 Place Sydney The Tribunal sets aside the decision under review, and in place of that decision determines that the applicant is entitled to pension at the Intermediate Rate provided for in s 23 of the Veterans’ Entitlements Act 1986 (Cth) with effect from 1 May 2014 and at the Special Rate provided for in s 24 of the Veterans’ Entitlements Act 1986 (Cth) with effect from 20 June 2014.
...............................[sgd].........................................
Ms N Isenberg, Senior Member
CATCHWORDS
VETERANS’ ENTITLEMENTS – disability pension – rate of pension payable – special rate – intermediate rate – the alone test – whether veteran incapable of undertaking remunerative work for eight or more hours per week – whether veteran prevented by accepted disabilities alone from continuing in remunerative work – decision under review set aside and substituted
LEGISLATION
Veterans’ Entitlements Act 1986 ss 5, 23, 24
CASES
Cavell v Repatriation Commission (1988) 9 AAR 534, [1998] FCA 464
Chambers v Repatriation Commission (1995) 55 FCR 9, (1995) 129 ALR 219
Flentjar v Repatriation Commission (1997) 48 ALD 1
Forbes v Repatriation Commission (2000) 101 FCR 50, [2000] FCA 328
Repatriation Commission v Buckingham, [1996] FCA 1218
Repatriation Commission v Hendy (2002) 76 ALD 47, [2002] FCAFC 424
Richmond v Repatriation Commission [2014] FCAFC 124Smith v Repatriation Commission [2014] FCAFC 53
REASONS FOR DECISION
Ms N Isenberg, Senior Member
16 September 2016
INTRODUCTION
The applicant, Brian Sharp served for over 20 years in the RAAF. He currently has accepted disabilities of sensorineural deafness, anxiety neurosis with phobic features, and bruxism.
On 17 April 2014 Mr Sharp sought an increase in his pension, in particular, the Special Rate of pension, provided for in s 24 of the Veterans’ Entitlements Act 1986 (the “VE Act”). A delegate of the Repatriation Commission refused that application but increased his pension to 90% of the General Rate. This decision was affirmed on review by the Veterans’ Review Board (“VRB”) in a reviewable decision dated 2 July 2015. Mr Sharp has applied for review of the VRB’s decision. His submission to this Tribunal is that he is entitled to the Special Rate of pension, or in the alternative the Intermediate Rate of pension, or that his pension should be at least increased to 100% of the General Rate.
Mr Sharp’s entitlement to the pension at the Special Rate is to be determined under s 24 of the VE Act.
LEGISLATIVE SCHEME
The criteria for payment of the Special Rate of pension are set out in s 24 of the VE Act. Generally speaking, if any one of the criteria is not met, the applicant will not be eligible for payment of pension at that rate. The Tribunal has no discretion in this regard. To qualify for pension at the Special Rate,…
Continue reading Sharp and Repatriation Commission (Veterans’ entitlements)
Sign in free to access the full text
- AGLC
- Sharp and Repatriation Commission (Veterans’ entitlements) [2016] AATA 719
- Case
- [2016] AATA 719
- Decision Date
CaseChat Overview and Summary
The primary legal issues before the Tribunal were whether Mr. Sharp's accepted disabilities alone rendered him incapable of undertaking remunerative work for eight or more hours per week, and whether these disabilities alone prevented him from continuing in his previous remunerative work, thereby causing a loss of earnings. The Tribunal was required to interpret and apply the "alone test" as established in case law, which dictates that even a minor contribution from a non-war-related factor to the inability to work will disqualify a veteran from these higher pension rates. The Tribunal also considered the scope of remunerative work that could be assessed, noting it was not limited to the veteran's previous employment or qualifications.
The Tribunal's reasoning focused on the composite test outlined in section 24 of the Act, particularly the "alone" requirement. Drawing on precedent, the Tribunal emphasised that the incapacity must be solely attributable to war-related conditions, meaning any other factor contributing to the inability to work, even if secondary, would prevent the satisfaction of the test. The Tribunal considered Mr. Sharp's extensive work history, his documented anxiety and phobic conditions, and the medical evidence detailing his struggles with stress, panic attacks, and alcohol use. Despite evidence suggesting Mr. Sharp's current lifestyle and potential for self-medication with alcohol might also impact his work capacity, the Tribunal concluded that his service-related anxiety neurosis, of itself, was sufficient to render him incapable of working more than eight hours per week and to prevent him from continuing in his former employment.
Consequently, the Tribunal set aside the decision under review. It determined that Mr. Sharp was entitled to pension at the Intermediate Rate from 1 May 2014 and at the Special Rate from 20 June 2014, reflecting the Tribunal's satisfaction that he met the criteria for these pension rates based on the impact of his accepted disabilities.
Orders
Orders of the court
Full text does not contain this section.
Background
Background to the litigation
Evidence
Evidence Before The Court
Decision
Reasons for decision
Ratio Decidendi
Legal Principle Established
Dr Smith was referred to the suite of anxiety disorders referred to in DSM III, which had been in operation at the time the applicant’s condition was accepted by the respondent as being related to his service. Some of the disorders (including panic disorder with agoraphobia) referred to a “complication” of psychoactive substance use disorders particularly alcohol. Dr Smith explained that that entry referred to a comment that a person may resort to, for example, alcohol as a means of self-medicating.CONSIDERATION In Smith v Repatriation Commission [2014] FCAFC 53 the Full Court said in relation to s 24 that: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 8 hours per week. Second, s 24(1)(c) requires that the veteran be prevented, by that incapacity alone (not for other reasons) from continuing earlier remunerative work. Third, s 24(1)(c) requires that prevention for that reason from continuing that work be the cause of a loss of earnings. Fourth, 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). With regard to the “alone” test, in an interpretation approved on appeal by the Full Court, the Federal Court stated in Richmond v Repatriation Commission [2014] FCAFC 124 ... if there is a non war-caused factor which prevents, or contributes to preventing, the veteran from continuing to undertake the relevant remunerative work, even if it is only of secondary weight and insufficient in itself to prevent the veteran from continuing, the “alone” test will not be satisfied.Does Mr Sharp’s anxiety neurosis with phobic features of itself alone render him incapable of undertaking remunerative work for periods aggregating more than 8 hours per week?: s 24(1)(b) This test requires an examination of the Applicant’s incapacity from his service-caused conditions to determine whether or not that incapacity is such, of itself alone, to render him incapable of undertaking remunerative work for the relevant duration. This does not require an examination of other causes that might render him unable to undertake remunerative work, but merely whether the service-caused disabilities, on their own, are sufficient to render him incapable of undertaking such work. Section 28 provides assistance in determining whether an Applicant is incapable of undertaking remunerative work by setting out the only matters that regard can be had to in deciding that question.What are Mr Sharp’s trade and professional skills, qualifications and experience? Section 24(1)(b) requires an examination of the applicant’s capacity to undertake remunerative work which he is physically and mentally able to carry out; the test is not limited to the type of work previously undertaken or for which the veteran is qualified by training or experience: Chambers v Repatriation Commission (1995) 129 ALR 219.