Woodroofe and Comcare (Compensation)

This matter concerned an appeal by Mr Woodroofe against a decision by Comcare to revoke its acceptance of liability for his adjustment disorder. Mr Woodroofe, employed by the Australian Federal Police (AFP), claimed his condition arose from his work as a police liaison officer with the ACT Policing COVID-19 Taskforce. The dispute centred on whether his condition constituted an "injury" under the *Safety, Rehabilitation and Compensation Act 1988* (SRC Act), specifically whether it was caused by reasonable administrative action taken in a reasonable manner.

The Tribunal was required to determine several issues: first, whether Mr Woodroofe suffered from an "ailment" or an aggravation of an ailment; second, if so, whether his employment with the AFP contributed to this ailment to a significant degree, thereby constituting a "disease"; third, whether this disease was suffered as a result of reasonable administrative action taken in a reasonable manner, which would exclude it from being an "injury" under the SRC Act; and finally, whether Comcare was liable to pay compensation under section 14 of the SRC Act.

The Tribunal found that Mr Woodroofe's condition, an adjustment disorder, was indeed an ailment. However, it then considered whether this ailment was suffered as a result of reasonable administrative action taken in a reasonable manner. The evidence indicated that following a meeting on 11 September 2021, Mr Woodroofe received aggressive communication from a colleague and was subsequently required to return to his substantive rank. The Tribunal concluded that these events constituted reasonable administrative action taken in a reasonable manner.

Consequently, the Tribunal determined that Mr Woodroofe had not suffered an "injury" as defined by the SRC Act, due to the exclusion for reasonable administrative action. Therefore, Comcare was not liable to pay compensation to Mr Woodroofe under section 14 of the SRC Act. The Tribunal affirmed the decisions under review.