Williams v Medi-Rent Pty Ltd - [2025] NSWPIC 563

CERTIFICATE OF DETERMINATION OF MEMBER
CITATION:	Williams v Medi-Rent Pty Ltd [2025] NSWPIC 563
APPLICANT:	Shaun Williams
RESPONDENT:	MEDI-RENT PTY LIMITED
MEMBER:	Fiona Seaton
DATE OF DECISION:	21 October 2025
CATCHWORDS:	WORKERS COMPENSATION -Workers Compensation Act 1987; claim for cost of dental treatment plan for acid erosion of teeth; the application of crowns on affected teeth disputed; alternative proposal of resin restorations; Held – the dental treatment proposed by the doctors including the application of crowns to the applicant’s affected teeth is reasonably necessary medical or related treatment as the result of the accepted injury pursuant to section 60.
DETERMINATIONS MADE:	The Personal Injury Commission determines: 1. the dental treatment proposed by Dr Hooi and Dr Jimenez is reasonably necessary as a result of injury on deemed date of injury 12 October 2021 pursuant to s 60 of the Workers Compensation Act 1987 (1987 Act), and 2. the applicant is entitled to payment of the costs of the proposed dental treatment plan proposed by Dr Hooi and Dr Jimenez including the application of crowns to his affected teeth pursuant to s 60 of the 1987 Act. The Personal Injury Commission orders: 3. The respondent to pay the costs of the dental treatment plan proposed by Dr Hooi and Dr Jimenez including the application of crowns to the applicant’s affected teeth. A brief statement is attached setting out the Commission’s reasons for the determination.

STATEMENT OF REASONS

BACKGROUND

When the applicant Mr Shaun Williams was employed by the respondent he sustained a psychological injury on or about 12 October 2021. As a result of that accepted injury he developed an eating disorder which led to damage to his teeth.
The applicant’s treating prosthodontist Dr Ken Hooi developed a dental treatment plan in 2023 to address tooth surface loss and associated decline in dentofacial aesthetics and destabilisation of the applicant’s occlusion. The proposal is for orthodontic treatment with Dr Vanessa Jimenez to extract supernumerary teeth, the reversal of occlusal destabilisation with fixed appliances (orthodontic braces), followed by porcelain crowns or veneers on the affected teeth.
The respondent issued a dispute notice under s 78 of the Workplace Injury Management and Workers Compensation Act 1998 (1998 Act) on 29 July 2024 disputing liability for resin replacement on some teeth on the basis that dental work is not causally related to the
12 October 2021 injury, and for the requested crowns or veneers on the basis that the treatment is not reasonably necessary as a result of the injury. Liability was accepted for resin replacement of teeth 12 to 23 only.
The second s 78 notice issued on 4 October 2024 disputes the requested treatment of extraction of upper right and left molars and a lower left molar, and fixed appliances for six teeth, as it has not been clearly identified as reasonably necessary to the recovery from the workplace injury.
The applicant made submissions to the insurer on 16 December 2024 and following internal review the dispute was maintained on 31…

Grounds of appeal

[14] The appellant contends that the primary judge erred in finding that the respondent had discharged the onus of establishing the matters required under the relevant provision.

[15] It was submitted that his Honour failed to give adequate weight to the evidence of the second witness, and that the findings of fact were not reasonably open on the material before the Court.

[16] The respondent, for its part, submits that no error is disclosed, and that the conclusions reached were well within the range of outcomes available to the primary judge.

Consideration

[17] It is convenient to deal first with the question of construction, as the resolution of that issue informs the remaining grounds advanced by the appellant.

[18] For the reasons that follow, we are of the view that the appeal should be allowed in part and the matter remitted for further determination.

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Details

Case: [2025] NSWPIC 563
Decision Date: 21 October 2025

CaseChat Overview and Summary

Williams has brought a claim against Medi-Rent Pty Ltd for the cost of a dental treatment plan for acid erosion of teeth, which he claims resulted from his employment. The primary dispute revolves around whether the application of crowns on the affected teeth is reasonably necessary treatment under the Workers Compensation Act 1987. Medi-Rent disputes this claim, proposing an alternative treatment of resin restorations instead. The court was tasked with determining whether the proposed treatment, including the application of crowns, qualifies as reasonably necessary medical or related treatment as a result of the accepted injury.

The central legal issue before the court was whether the proposed dental treatment, including the application of crowns, is reasonably necessary treatment under section 60 of the Workers Compensation Act 1987. The court had to consider the medical evidence provided by the treating dentists and weigh it against the alternative proposal by Medi-Rent. It was necessary to assess the reasonableness of the proposed treatment in light of the accepted injury and the medical necessity of the treatment to determine whether it met the criteria for compensation under the Act.

The court found that the treatment proposed by the applicant’s doctors, including the application of crowns on the affected teeth, is reasonably necessary medical or related treatment. This conclusion was based on the medical evidence presented, which demonstrated the necessity of such treatment to address the specific dental issues arising from the accepted injury. The court rejected Medi-Rent's proposal of resin restorations as an alternative, finding it insufficient to adequately address the applicant’s condition. Consequently, the court ruled in favour of the applicant, finding that the proposed treatment is reasonably necessary.

The court ordered Medi-Rent Pty Ltd to pay the costs associated with the dental treatment plan, including the application of crowns on the applicant’s affected teeth, as reasonably necessary medical or related treatment under the Workers Compensation Act 1987. The court’s decision underscores the importance of considering the specific medical needs of the injured worker and the necessity of the proposed treatment in determining compensation claims.

Orders