Zivanovic and Comcare (Compensation) [2020] AATA 343 (27 February 2020)
Division:GENERAL DIVISION
File Numbers: 2016/4553
2017/7357
2017/7356
Re:Vladimir Zivanovic
APPLICANT
AndComcare
RESPONDENT
DECISION
Tribunal:Dr Stewart Fenwick, Senior Member
Date:27 February 2020
Place:Melbourne
The Tribunal:
(a)In application 2016/4553:
(i)Sets aside the reviewable decision and remits the matter for reconsideration of entitlements under the Safety, Rehabilitation and Compensation Act 1988 with the direction that:
A.the Applicant continues to suffer from an aggravation of pre-existing patellofemoral dysplasia in his left knee;
B.the Applicant’s condition of secondary hypertension was not contributed to, to a significant degree, by his employment;
(ii)costs in this application reserved.
(b)Affirms the decisions in applications 2017/7356 and 2017/7357.
....[sgd]....................................................................
Dr Stewart Fenwick, Senior Member
Catchwords
COMPENSATION — degenerative osteoarthritis in both knees and lumbar spine – hypertension – prior acceptance of aggravation of underlying left knee condition – prior acceptance of liability for right total knee replacement – whether conditions caused by altered gait and/or medical treatment – whether conditions contributed to, to a significant degree, by employment – impact of age and weight on conditions – first decision set aside and remitted – second and third decisions affirmed
Legislation
Administrative Appeals Tribunal Act 1975
Safety, Rehabilitation and Compensation Act 1988Safety, Rehabilitation and Compensation and Other Legislation Amendment Act 2007
Cases
Brackenreg v Comcare (2010) 187 FCR 209
Comcare v Power (2015) 238 FCR 187
Comcare v Sahu-Kahn (2007) 156 FCR 536
Commonwealth v Borg [1991] FCA 710Prain and Comcare (Compensation) [2016] AATA 459
REASONS FOR DECISION
Dr Stewart Fenwick, Senior Member
27 February 2020
BACKGROUND
Mr Zivanovic applied on 26 August 2016 (the 2016 application) for review of a decision of a Review Officer of Comcare dated 27 June 2016, affirming an earlier determination, dated 11 April 2016, that Comcare had no present liability for medical expenses, incapacity payments, and household services and attendant care in relation to an accepted claim for aggravation of a left knee condition and secondary hypertension (the no present liability decision).[1]
[1] Tribunal file number 2016/4553.
In related applications dated 13 December 2017 (the 2017 applications), Mr Zivanovic sought review of the following decisions affirming determinations by Comcare in which liability was declined:
(a)On 8 December 2017, a Review Officer of Comcare affirmed a determination dated 9 October 2017 to decline liability for medications related to hypertension and cholesterol management;[2] and
(b)On 8 December 2017, a Review Officer of Comcare affirmed a determination dated 6 October 2017 to decline liability for a lumbar spine condition and a total right knee replacement.[3]
These conditions were the subject of claims lodged on Mr Zivanovic’s behalf by his legal representatives in the course of the 2016 application.
[2] Tribunal file number 2017/7356.
[3] Tribunal file number 2017/7357.
Mr Zivanovic suffered an injury to his left knee on 3 August 1990 while riding a tram in the course of his employment as a clerk in a Commonwealth agency. Mr Zivanovic is currently 63 years old and according to medical opinion,…
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CaseChat Overview and Summary
The legal issues before the Tribunal were whether the degenerative conditions of Mr Zivanovic's lumbar spine and right knee were caused by his employment, either directly or indirectly through altered gait and medical treatment following his accepted left knee injury. The Tribunal also had to consider the impact of non-employment related factors, specifically Mr Zivanovic's age and morbid obesity, on the development and progression of these conditions. Crucially, the Tribunal needed to apply the correct causal test, which required satisfaction that an employment-related factor contributed to the conditions to a "significant degree," defined as substantially more than material.
The Tribunal reasoned that it needed to be positively satisfied that the original injury caused or contributed to the conditions for which compensation was sought, and that the fact compensation had previously been paid did not alter this requirement. The Senior Member noted that the test for contribution had been strengthened to require a "significant degree," meaning substantially more than material, and that this needed to be assessed in light of all relevant factors, including those specified in section 5B(2) of the Act. The Tribunal considered medical evidence suggesting that morbid obesity was a primary cause of the lumbar spine condition and that this was biochemically influenced, not solely due to physical forces. The Tribunal also noted that Mr Zivanovic's right knee replacement was accepted as due to altered load bearing from the principal left knee injury, and that subsequent back pain was attributed to changes in load bearing post-operation.
The Tribunal set aside the first decision and remitted it for reconsideration, while affirming the second and third decisions. This outcome indicates that the Tribunal found the initial assessment of liability for some conditions to be flawed, necessitating a fresh determination, but upheld Comcare's decisions regarding other conditions.
Orders
Orders of the court
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Background
Background to the litigation
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Evidence
Evidence Before The Court
Decision
Reasons for decision
Ratio Decidendi
Legal Principle Established
I asked Dr McGrath to clarify the relationship between osteoarthritis and obesity. He stated that there are risk factors relating to glucose in the body and the production of cartilage. It is not just a matter of physical forces, but also the biochemistry involved. CONSIDERATIONS Given the claims history and the evidentiary issues, it is helpful to state some key propositions that I take from the authorities. I consider that I need to be persuaded that the circumstances giving rise to entitlement under the Act exist (Commonwealth v Borg [1991] FCA 710, [16]). There is no onus of proof as such (Comcare v Power (2015) 238 FCR 187, 197 [57]–[58]), but I need to be positively satisfied that the original injury caused or contributed to the conditions for which treatment is sought, or expense incurred (Brackenreg v Comcare (2010) 187 FCR 209, 223 [62]–[64]). The fact that compensation has already been paid does not change this approach. As will be seen below, the nature of the contribution made to Mr Zivanovic’s conditions by different factors is a critical concern in this matter. Accordingly it is necessary to briefly refer to the authorities relating to the relevant causal tests. I accept that the change to the degree of contribution required for a disease to qualify as an injury under the Act strengthened the causal relationship with employment. The new test of contribution ‘to a significant degree’ is defined with reference to language used in the previous test, which was contribution to a ‘material degree’. That is, significant degree is defined as ‘substantially more than material’. This definition invites consideration of ‘material’ and this was undertaken by Finn J in Comcare v Sahu-Kahn (2007) 156 FCR 536. His Honour found that the word must be interpreted in the context of the relevant factors, and that whether the threshold is met is a matter of fact and degree (at 542–3 [16]). His Honour also discussed dictionary definitions, which include the word ‘substantial’ (at 542 [15]); the very qualifying word chosen when the test was amended. What I take, then, from the introduction of the new causal test is recognition that there must be something more than a mere causal relationship between a factor and a condition. The addition of the word ‘significant’ reinforces this, emphasising that any contribution of an employment related factor must be substantial. Furthermore, the test needs to be applied in the context of at least those factors specified in s 5B(2) of the Act. Adapting the reasoning of the Tribunal in Prain and Comcare (Compensation) [2016] AATA 459 at [70], where there are a range of significant factors, the inquiry might take the form: ‘is an employment related factor a significant contributor to the condition’? I accept that, under the Act, Mr Zivanovic’s conditions are all to be understood as ‘diseases’. Given the years spanned by the conditions, and the medical evidence, it is necessary to determine, where possible, when the conditions arose. This is because there are two different causal tests that might apply. Left Knee