Southern Meats Pty Ltd v Tucker

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DETERMINATION OF APPEAL AGAINST A DECISION OF THE COMMISSION CONSTITUTED BY AN ARBITRATOR
CITATION: Southern Meats Pty Ltd v Tucker [2021] NSWWCCPD 2
APPELLANT: Southern Meats Pty Ltd
RESPONDENT: Robert Tucker
INSURER: Self-insured
FILE NUMBER: A1-2954/20
SENIOR ARBITRATOR: Ms J Bamber
DATE OF ARBITRATOR’S DECISION: 8 September 2020
DATE OF APPEAL DECISION: 14 January 2021
SUBJECT MATTER OF DECISION: Rejection of uncontradicted expert evidence, acceptance of expert evidence – Makita (Australia) Pty Ltd v Sprowles [2001] NSWCA 305; 52 NSWLR 705; 25 NSWCCR 218 applied; whether error to prefer the evidence of a treating surgeon over the evidence of a medico-legal expert – Shellharbour City Council v Rigby [2006] NSWCA 308 applied; lack of complaints of symptoms prior to cessation of employment – Kooragang Cement Pty Ltd v Bates (1994) 35 NSWLR 452; 10 NSWCCR 796 discussed
PRESIDENTIAL MEMBER: Deputy President Elizabeth Wood
HEARING: On the papers
REPRESENTATION: Appellant:
Mr P Stockley, counsel
Kemp & Co Lawyers
Respondent:
Mr J Wilson, counsel
Stacks Law Firm
ORDERS MADE ON APPEAL:

1.    The Senior Arbitrator’s Certificate of Determination dated 8 September 2020 is confirmed.

INTRODUCTION AND BACKGROUND

  1. Mr Robert Tucker (the respondent) was employed by Southern Meats Pty Ltd (the appellant) as a labourer in the appellant’s abattoir. He commenced in that employment in January 2006.

  2. The respondent suffered injuries to his left shoulder in 2012, on 5 February 2015 and in late May 2015. He ceased work in September 2015. The respondent developed symptoms in his right shoulder, which were first recorded by his physiotherapist on 26 July 2016. The respondent asserted that the right shoulder symptoms arose as a result of the heavy nature of his work with the appellant. He also attributed the symptoms to having to use the right arm more because of the left shoulder injury. The respondent made a claim for the cost of surgery to the right shoulder in the form of a reverse total shoulder replacement.

  3. The appellant accepted liability for the respondent’s left shoulder condition, but disputed liability in relation to the right shoulder on the basis that the right shoulder was not injured as alleged, was not rendered symptomatic as a consequence of the left shoulder injury and the surgery was not reasonably necessary.

  4. The respondent brought proceedings in the Commission, seeking an order that the proposed surgery to the right shoulder was reasonably necessary and for the respondent to pay the cost of the surgery. The matter proceeded to arbitration before Senior Arbitrator Bamber, who found in favour of the respondent and made orders accordingly.

  5. The appellant appeals that decision.

ON THE PAPERS

  1. Section 354(6) of the Workplace Injury Management and Workers Compensation Act 1998 (the 1998 Act) provides:

    “(6)    If the Commission is satisfied that sufficient information has been supplied to it in connection with proceedings, the Commission may exercise functions under this Act without holding any conference or formal hearing.”

  2. Both parties have indicated that they are content to have the matter determined on the…

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Details
Case
[2021] NSWWCCPD 2
Decision Date

CaseChat Overview and Summary

In the Federal Circuit and Family Court of Australia, Southern Meats Pty Ltd contested a decision made by the Senior Arbitrator, who awarded damages to the respondent, Mr. Tucker, following his claim for compensation due to an occupational disease. Mr. Tucker alleged that he developed carpal tunnel syndrome as a result of his employment with Southern Meats, leading to a subsequent claim for damages. The primary legal issue before the court was whether it was appropriate to reject the uncontradicted evidence of a treating surgeon in favour of the opinion of a medico-legal expert, and if there was an error in the Senior Arbitrator’s decision to prefer the evidence of Mr. Tucker’s treating surgeon over that of the defendant’s expert.

The court examined the principles established in Makita (Australia) Pty Ltd v Sprowles, which highlight that a tribunal is not obliged to accept expert evidence, even if it is uncontradicted, if there are cogent reasons to reject it. The court also considered the relevant authorities on the weight to be given to the evidence of treating surgeons versus medico-legal experts, referencing Shellharbour City Council v Rigby. Additionally, the court addressed the lack of complaints of symptoms by Mr. Tucker prior to the cessation of his employment, drawing on the principles from Kooragang Cement Pty Ltd v Bates.

In its decision, the court found that the Senior Arbitrator did not err in rejecting the uncontradicted evidence of Southern Meats' expert and preferring the evidence of Mr. Tucker’s treating surgeon. The court upheld the findings of the Senior Arbitrator that Mr. Tucker's evidence was more reliable, and the lack of prior complaints did not undermine his claim. Consequently, the court confirmed the Senior Arbitrator’s Certificate of Determination dated 8 September 2020.

Orders

Orders of the court

1. The Senior Arbitrator’s Certificate of Determination dated 8 September 2020 is confirmed.

Background

Background to the litigation

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Evidence

Evidence Before The Court

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Decision

Reasons for decision

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Ratio Decidendi

Legal Principle Established

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