FEDERAL COURT OF AUSTRALIA
Wuth v Comcare [2022] FCAFC 42
Appeal from: Wuth and Comcare (Compensation) [2020] AATA 3625 File number(s): ACD 49 of 2020 Judgment of: GRIFFITHS, WHEELAHAN AND SNADEN JJ Date of judgment: 22 March 2022 Catchwords: WORKERS’ COMPENSATION – appeal from a decision of the Administrative Appeals Tribunal heard by the Full Court in the court’s original jurisdiction – where the Tribunal determined that the applicant did not suffer an “injury” for the purposes of s 14 of the Safety, Rehabilitation and Compensation Act 1988 (Cth) (Act) and therefore that Comcare was not liable to pay her compensation – where the Tribunal found that the applicant suffered from chronic daily headaches which were materially contributed to by her former employment, but which were not supported by identifiable physiological change – whether an identifiable physiological change is required to establish a “disease” as a criteria of an “injury” – consideration of Military Rehabilitation and Compensation Commission v May [2016] HCA 19; 257 CLR 468 – identifiable physiological change not required to establish a “disease” – on the facts found by the Tribunal, the applicant suffered a “disease”.
ADMINISTRATIVE LAW – appeal from the Tribunal’s decision to affirm Comcare’s calculation of normal weekly earnings pursuant to s 8(5) of the Act – where the Tribunal approached the review by reference to previous judgments in proceedings between the parties given by a single judge and by the Full Court concerning s 8(1) of the Act, and reached its conclusion based upon speculation as to how that single judge and Full Court would have addressed the relevant questions under s 8(5) – the Tribunal failed to direct itself to the correct questions, failed to engage with the parties’ submissions, and misapplied the relevant judgments – application remitted for rehearing.
Legislation: Administrative Appeals Tribunal Act 1975 (Cth) ss 34D(2), 44, 44(3)(b) and 44(7)
Safety, Rehabilitation and Compensation Act 1988 (Cth) ss 4, 4(1), 5B, 7(4), 8, 8(1) and 8(2), 8(5), 8(10), 9, 14, 19, 19(1) and (2), 20, 21, 21A, 24, 27, 28, 53(1), 60(1), 62, 64, 67, 69(a) and 72(a)
Workers’ Compensation Act 1951 (ACT) ss 7(1), 9(1)
Cases cited: Accident Compensation Commission v McIntosh [1991] 2 VR 253
Australian Postal Corporation v Burch (1998) 85 FCR 264
Ball v William Hunt & Sons Ltd [1912] AC 496
Canute v Comcare [2006] HCA 47; 226 CLR 535
Comcare v Canute [2005] FCAFC 262; 148 FCR 232
Comcare v Mooi (1996) 69 FCR 439
Comcare v Wuth [2017] FCA 433; 72 AAR 84
Comcare v Wuth [2018] FCAFC 13; 260 FCR 89
Comcare v Wuth (No 2) [2018] FCAFC 60
Commonwealth v Hornsby (1960) 103 CLR 588
Commonwealth v Snell [2019] FCAFC 57; 269 FCR 18
Favelle Mort Ltd v Murray (1976) 133 CLR 580
Hetherington v Amalgamated Collieries of WA Ltd (1939) 62 CLR 317
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- Wuth v Comcare [2022] FCAFC 42
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- [2022] FCAFC 42
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CaseChat Overview and Summary
The Full Court reviewed the Tribunal's approach to the question of whether Wuth had suffered a compensable injury. It noted that the Tribunal found Wuth's headaches were materially contributed to by her employment, but that there was no identifiable physiological change. The Full Court clarified that an identifiable physiological change is not required to establish a disease for the purposes of the Act, following the decision in Military Rehabilitation and Compensation Commission v May. Given the Tribunal's findings, the Full Court concluded that Wuth had indeed suffered a disease that was caused by her employment, and thus a compensable injury. Regarding the calculation of normal weekly earnings, the Full Court found that the Tribunal misapplied previous judgments and failed to properly engage with the submissions of the parties. The Tribunal's approach was speculative, and it did not direct itself to the correct questions. Consequently, the Full Court set aside the Tribunal's decision and remitted the matter for rehearing. The Full Court also ordered that the costs of the appeal be reserved for determination upon remittal and that Comcare pay Wuth's costs of the proceeding.
Orders
Orders of the court
1. The appeal be allowed.
2. The decision of the Administrative Appeals Tribunal in application 2018/4238, affirming Comcare’s decision dated 27 July 2018, is set aside.
3. Application 2018/4238 is remitted to the Administrative Appeals Tribunal to be heard and decided again, in accordance with these reasons and otherwise according to law.
4. The costs to date in application 2018/4238 be reserved to the Administrative Appeals Tribunal for determination upon remittal.
5. The respondent pay the applicant’s costs of this proceeding.
Note: Entry of orders is dealt with in Rule 39.32 of the Federal Court Rules 2011.
Background
Background to the litigation
Evidence
Evidence Before The Court
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Decision
Reasons for decision
Ratio Decidendi
Legal Principle Established
Section 62 provides that a “determining authority” may reconsider a determination –62 Reconsideration of determinations(1)A determining authority may, on its own motion:(a)reconsider a determination made by it;(b)cause such a determination to be reconsidered by a person to whom its power under this section is delegated, being a person other than the person who made, or was involved in the making of, the determination;whether or not a proceeding has been instituted or completed under this Part in respect of a reviewable decision made in relation to that determination.(2)A request to a determining authority to reconsider a determination made by it may be made by:(a)the claimant; or(b)if the determination affects the Commonwealth—the Commonwealth; or(c)if the determination affects a Commonwealth authority—that Commonwealth authority.…(5)Where a person reconsiders a determination, the person may make a decision affirming or revoking the determination or varying the determination in such manner as the person thinks fit. Sub-section 60(1) defines “determining authority” in relation to a determination as the person who made the determination. Section 64 provides for application to be made to the Tribunal for review of a “reviewable decision”, which is defined by s 60(1) as including a decision made under s 62.Background The applicant was employed by the Commonwealth for a number of years. In December 2005, when the applicant worked in Canberra at the Department of Health and Ageing, she contracted a viral condition, referred to as Epstein-Barr virus, which resulted in migraine headaches. This condition was not alleged to be work-related. On 14 November 2006, the applicant accepted an offer of permanent re-assignment from the Department of Health and Ageing to the Department of Finance and Administration (as it was then known) with effect from 27 November 2006. The offer of re-assignment stated that the applicant’s employment would be part-time at 29.4 hours per week. A payroll check list that was in evidence noted that the applicant would be working Monday, Tuesday, Thursday and Friday. The applicant and the Secretary of the Department of Finance and Administration entered into an Australian Workplace Agreement under the Workplace Relations Act 1996 (Cth). The applicant executed the Agreement on 31 May 2007, and a delegate or agent of the Secretary executed the Agreement on 18 June 2007. As to the applicant’s hours of work, the Agreement provided –2.3 Hours of workYou are required to work ordinary hours and such reasonable additional hours as are necessary for the performance of your duties. Your ordinary hours are 36 hours and 45 minutes per week or 7 hours and 21 minutes per day, subject to any part-time arrangements agreed between you and your Manager. If you work part-time your remuneration (salary and any performance bonus) and leave entitlements will be calculated on a pro rata basis, based on the full-time ordinary hours.Your remuneration includes payment for all hours worked, including reasonable additional hours. The relevant period for the purposes of calculating the average hours you work shall be 12 months.Time Off In Lieu (TOIL) may be granted by your Manager in consultation with the General Manager to recognise short term additional hours worked.Supplementary leave may be determined by the Remuneration Committee to recognise additional hours spent on specific, approved projects.