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[1998] VSC 29
Supreme Court of Victoria
1998-08-13
McDONALD, J.
Original judgment source is linked above.
Accident compensation, weekly payments - Totally and permanently incapacitated - Meaning of permanent - Issue estoppel - Accident Compensation Act 1985 ss.93B(1)(a) - (c), 2(a), (3) and (4); 114(2)(b)(ii)
"(1) A worker is entitled, subject to and in accordance with this part, to weekly payments while incapacitated for work (not being a period during the first 26 weeks of incapacity) at which ever of the following rates apply - "
"(1) The authorised insurer, authority or self-insurer may in accordance with this act terminate a worker's entitlement to weekly payments or alter the basis on which the amount of the weekly payment is to be calculated whether or not the worker is currently receiving weekly payments".
"(2) In addition to other grounds under this Act for termination or alteration of weekly payments, the authorised insurer, authority or self-insurer -
(a) ...
(b) may terminate weekly payments on the ground that -
(i) ...
(ii) the worker is not or is no longer entitled to weekly
payments;"
"After considering all available information we have determined that you are no longer entitled to weekly payments (section 114(2)(b)(ii)) as:
- you did not make every reasonable effort to participate in an
occupational rehabilitation service or return to work plan.
(Section 93B(2)(a)(ii) & 93B(4))."
"(2) A worker is entitled to receive weekly payments under this section only if -
(a) where sub-s.(1)(a) applies, the worker
(i) ...
(ii) where the medical and other evidence indicates it is
desirable, makes every reasonable effort to
participate in approved occupational rehabilitation
service or return to work plan;"
"Where a worker does not make reasonable efforts to return to work and in particular does not comply with the requirements of sub-section (2) that are applicable in his or her case, the worker's entitlement to further weekly payments in respect of the injury shall thereupon cease and determine."
"(1) Weekly payments to be reinstituted at the serious injury rate (90%) (PIAWE) from 9/2/96 to continue in accordance with law.
(2) The defendant to pay plaintiff interest on payments under s.114E(1)(c) of the Accident Compensation Act.
(3) Defendant to pay plaintiff's costs on Magistrates' Court scale E including all reserve costs.
(4) Costs fixed for hearing on 23/7/97 at $300."
"Did the learned magistrate err in law in holding that the decision made by him on 30 November 1994 estopped the appellant from terminating payments of compensation on the ground that the respondent did not make every reasonable effort to participate in an occupational rehabilitation service or return to work plan (section 93B)."
"A judicial determination directly involving an issue of fact or of law disposes once for all of the issue, so that it cannot afterwards be raised between the same parties or their privies. The estoppel covers only those matters which the prior judgment, decree or order necessarily established as the legal foundation or justification of its conclusion, whether that conclusion is that a money sum be recovered or that the doing of an act be commanded or be restrained or that rights be declared. The distinction between res judicata and issue estoppel is that in the first the very right or cause of action claimed or put in suit has in the former proceedings passed into judgment, so that it is merged and has no longer an independent existence, while in the second, for the purpose of some other claim or cause of action, a state of fact or law is alleged or denied the existence of which is a matter necessarily decided by the prior judgment, decree or order."
"Of the three classes of privies of blood, of title and of interest, the only one which is submitted and indeed could be submitted to be relevant is that of a privy in interest. ... The basic requirement of a privy in interest is that the privy must claim under or through the person of whom he is said to be a privy."
In Carl-Zeiss-Stiftung v. Rayner (No.3) [1970] Ch.506 at 541 Buckley, J suggested that for there to be a privy in interest between a party to proceedings and another who is not party to the proceedings, the outcome of such proceedings must confer a benefit or impose an obligation on the other who is not party to the proceedings.
"Total incapacity" was defined under s.5 of the Act to mean -
"in relation to a worker means an inability arising from an injury such that the worker is not able to return to work either in the worker's pre-injury employment or in suitable employment".
"in relation to a worker, means employment in work for which the worker is suited (whether or not that work is available), having regard to the following -
(a) the nature of the worker's incapacity and pre-injury
employment;
(b) the worker's age, education, skills and work experience;
(c) the worker's place of residence;
(d) the details given in medical information including the
medical certificates supplied by the worker;
(e) the worker's return to work plan, if any;
(f) if any occupational rehabilitational services are being
provided to or for the worker".
"A person above the age of 16 years who ... is permanently incapacitated for work ... shall be qualified to receive an invalid pension".
"The vital contrast between temporary and permanent incapacity must be based upon an assessment of future prospects at the time the decision is made. It is not inconsistent with the notion of permanent incapacity that the pensioner's position should be reviewed from time to time. Unexpected improvement in the person's condition, advances in medical science, the achievement of fresh skills, or even changes in the labour market, could bring to an end an incapacity which had been thought to be permanent.
In my view the true test of a permanent, as distinct from a temporary, incapacity is whether in the light of the available evidence, it is more likely than not that the incapacity will persist in the foreseeable future."
"(1) If there is caused to a worker an injury arising out of or in the course of any employment and if the worker's employment was a significant contributing factor the worker shall be entitled to compensation in accordance with this Act".
"If a worker's incapacity for work results from or is materially contributed to by an injury which entitles the worker to compensation the compensation shall be in the form of weekly payments subject to and in accordance with this part".
"(3) The worker's entitlement to weekly payments under this section ceases after the worker has been incapacitated for 104 weeks unless the worker -
(a) has a serious injury; or
(b) is totally and permanently incapacitated.
(4) Where a worker does not make reasonable efforts to return to work and in particular does not comply with the requirements of sub-section (2) that are applicable in his or her case, the worker's entitlement to further weekly payments in respect of the injury shall thereupon cease and determine."
I certify that this and the 17 preceding pages are a true copy of the reasons for judgment of McDonald, J of the Supreme Court of Victoria delivered on 13 August 1998.
AMP Workers Comp. Services Ltd
Chalkley [1998] VSC 29