Cameron v Nursing and Midwifery Council of NSW [2026] NSWCATOD 42;

1. Ms Cameron is entitled to appeal the Council's decision to impose conditions on her registration under s 159(1)(b) of the National Law.
2. Appeals of this kind are dealt with by way of a new hearing and fresh evidence or evidence substituting or in addition to the evidence before the Council at the time it made its decision, that is the effect of s 159(3) of the National Law. Accordingly, while the findings of the s 150 Hearing panel are informative, they are not in any way determinative of these proceedings. One consequence of the nature of an appeal of this kind is that to the extent the reasoning of the panel convening the s 150 Hearing gave rise to an error of law, any such error falls away or is overcome by the exercise of rehearing: Steel v Medical Council of New South Wales [2020] NSWCATOD 77 at [34].
3. The Tribunal conducted a hearing over two days, received oral and documentary evidence tendered by both parties, considered the parties' written submissions, and heard oral submissions, including submissions in reply. Ms Cameron represented herself throughout the proceedings and was permitted to have a support person sit with her during the hearing.
4. Subsequently, in mid-January 2026, the Tribunal made orders for the filing of submissions and evidence regarding some further evidence Ms Cameron sought to rely on. Ms Cameron was directed to file and serve her further submissions by 23 January 2026, and the Respondent was directed to file and serve its submissions by 10 February 2026. The Tribunal received materials from both parties in response to those directions.
5. Since those orders were fulfilled, Ms Cameron has continued to send voluminous material to the Tribunal registry by email. At the date of publication of these reasons, she had sent five emails, containing at least 12 further documents as attachments. We have declined to have regard to material filed after the dates directed by the Tribunal.

1. The issue to be determined in these proceedings is whether the Tribunal is satisfied, on the evidence before it, that it is necessary to impose conditions on Ms Cameron's registration, either:

(1) For the protection of the health and safety of any person or persons; or

(2) Because the imposition of conditions is otherwise in the public interest.

1. For the reasons that follow, we have concluded that it is necessary to impose the same condition on Ms Cameron's registration as the Council had originally imposed because it is in the public interest to do so. That condition means that Ms Cameron is not permitted to practise as a registered nurse.
2. An ancillary issue is whether Ms Cameron should be ordered to pay the Council's costs of the proceedings. We have determined that Ms Cameron should bear the costs of the proceedings, and our reasons for this are set out below.

1. The NSW Court of Appeal, in its unanimous reasons in Medical Council of New South Wales v Smithson [2021] NSWCA 53 (Smithson), set out the relevant principles in respect of an appeal under s 159 of the National Law. At [20], the Court of Appeal said:

"... it is appropriate first to set out the principles applicable to the determination of an appeal under s 159. Those principles have been extensively discussed in recent decisions of this Court in Ghosh v Medical Council of New South Wales (2020) 102 NSWLR 303; [2020] NSWCA 122 and Kirby v Dental Council of NSW [2020] NSWCA 91. The most important are:

(1) The role of the Tribunal in a s 159 appeal of the present kind is to apply s 150 standing in the shoes of the Council. The hearing is de novo and not limited to evidence before the Council. The legal standard to be applied is fixed by s 150: Kirby at [117]-[119]; Ghosh at [9].

(2) The subject matter, scope and purpose of s 150 makes clear that it is a protective provision with two independent limbs. The touchstone for the exercise of the Council's role under s 150(1) to make an order suspending the practitioner's registration or imposing conditions on it is that the Council be satisfied that it is appropriate to do so for (i) the protection of the health or safety of any person or persons (the first limb), or (ii) that the action is otherwise in the public interest (the second limb): Kirby at [15]; Ghosh at [5]. The two limbs may overlap but the public interest is not subsumed in the first limb: see Pharmacy Council of NSW v Ibrahim [2020] NSWSC 708 at [35]. The two limbs are disjunctive; satisfaction of either will suffice to trigger the obligation imposed by s 150.

(3) The proceedings are not disciplinary and are not necessarily referable to a complaint. The National Law otherwise makes provision for dealing with complaints against registered health practitioners: see Div 3 Subdivs 2-6. The function of a s 150 Hearing is purely protective in character: Kirby at [15]; Ghosh at [5]. By s 150D, a Council must, after taking action under s 150(1) (except in the case of impairment), refer the matter to the Health Care Complaints Commission ("HCCC") to be investigated as a complaint. By s 150F, in a case of impairment, the Council must consult with the HCCC to see if agreement can be reached as to whether the matter should be dealt with as a complaint or referred to an Impaired Registrants Panel: Ghosh at [3].

...

(5) Because the circumstances in which action under s 150 may be taken include that there may be a continuing dispute as to the relevant facts and that investigations into complaints concerning the practitioner by bodies such as the HCCC may not have been completed or even commenced, the Tribunal is not required to make conclusive findings of fact based on the material before it. The s 159 hearing does not involve determination of the merits of a claim: Kirby at [14], [139]; Ghosh at [9].

(6) The role of the Tribunal is to make an assessment of the evidence and determine whether it is satisfied that it is appropriate to make one of the orders referred to in s 150(1). The s 159 hearing is not the occasion to consider, let alone determine, whether a practitioner is currently a fit and proper person to carry on the role: Ghosh at [9].

(7) The "protection of the health and safety of any person or persons" does not require there be actual harm suffered by any person. Because s 150 is concerned with protection, it is sufficient if it can be demonstrated that there is a potential for harm: Ghosh at [9]. The Tribunal's role in this case was to make an assessment of the evidence and determine whether it was appropriate, on either of the bases for which s 150 provides, that an order be made under s 150 for the protection of the health or safety of any person or persons or otherwise in the public interest.

(8) As s 150 is a protective provision, it is appropriate ordinarily for the Tribunal, in deciding whether it is satisfied that it is appropriate to make an order under the first or second limb, to make an assessment about the nature and degree of risk to the health or safety of any person or persons or to the public interest (in the sense of the chance of the suggested harm being realised) and the consequences of the suggested harm being realised (in the sense of the seriousness of the harm that will ensue if the risk is realised): see X v The Commonwealth (1999) 200 CLR 177; [1999] HCA 63 at [41], which addresses risk in a different context. Reaching that state of satisfaction involves the Tribunal making an assessment of all of the evidence before it.

(9) The essential question which the proper conduct of a s 159 hearing de novo requires the Tribunal to address is whether allowing the medical professional to practise, or to practise with certain conditions, involves an unacceptable risk to the health and safety of the public, or otherwise involves an unacceptable risk to the public interest: Ghosh at [103]."

1. Without re-stating the comprehensive principles above, it is apparent that the Tribunal's determination is focused on the protection and safety of the public. These are not disciplinary proceedings; nor are they a critique of Ms Cameron's conduct or an admonishment of her decisions or behaviour.
2. Notably, our inquiry does not, as Ms Cameron had submitted, require that we find evidence of actual harm to a patient. That is because, as observed in Smithson and in Ghosh, it is sufficient if the potential for harm can be demonstrated. The Tribunal must then move to assess the degree or nature of the risk and the consequences of the suggested harm being realised. Effectively, the Tribunal is assessing risk, based on the evidence before it.
3. In considering the protection and safety of the public, we have referred from time to time to the Nursing and Midwifery Board of Australia Registered Nurse Standards for Practice, 1 June 2016 (Standards for Practice). The Standards for Practice apply across all areas of nursing practice and are read in conjunction with applicable codes of conduct and other guidelines; they expressly support the Code of Conduct for Nurses. Accordingly, they form part of the framework of expected conduct and responsibility for registered nurses. The Standards for Practice are, among other things, supposed to be evident in the current practice of registered nurses and inform their aspirations. We have used the Standards of Practice as one point of reference (among others) to assist in our consideration of the primary questions we are required to consider under s 150 of the National Law. Our consideration of the Standard for Practice is always subject to the matters we are required to consider under the National Law.
4. There are seven aggregate standards, which are interrelated, and we have listed them here:

(1) Thinks critically and analyses nursing practice;

(2) Engages in therapeutic and professional relationships;

(3) Maintains the capability for practice;

(4) Comprehensively conducts assessments;

(5) Develops a plan for nursing practice;

(6) Provides safe, appropriate and responsive quality nursing practice; and

(7) Evaluates outcomes to inform nursing practice.

1. For the purposes of these proceedings, we consider that the most relevant of these are Standards of Practice 1, 2 and 3. As necessary, we have referred to those standards as part of our consideration of the risks posed by Ms Cameron to the health and safety of a person or persons and to the public interest.

1. The Tribunal was provided with the evidence put before the s 150 Hearing as well as further material supplied by both parties. All of the material relied upon by the Tribunal in making its determination was marked as exhibits in the course of the hearing.
2. Among the documentary materials were expert reports from Dr Keller and Dr Naidoo. There were two expert reports from Dr Keller, an appropriately qualified consultant psychiatrist with specialist expertise in adult psychiatry (among other specialisations), and a report from Dr Prem Naidoo, a qualified consultant psychiatrist to whom Ms Cameron was referred by her general practitioner and attended six interviews with her in April, May (two), June, July and November 2025. The second of Dr Keller's reports considers and responds to Dr Naidoo's report and opinions.
3. Ms Cameron, Dr Keller, and Ms Cameron's general practitioner, Dr Cholakyan, each gave oral evidence at the hearing. Dr Naidoo was not available for cross-examination at the hearing.
4. We now set out our factual findings arising from the evidence before the Tribunal.

1. After receiving formal training, Ms Cameron was first registered as a nurse in 1982. She worked as a registered nurse in both Australia and the United Kingdom. In the hearing, Ms Cameron produced written references from that period.
2. From about 1995 until late 2023, Ms Cameron principally worked as a clinical nurse consultant and diabetes educator at various hospitals and clinics in NSW. As part of this work, Ms Cameron has operated under a provider number issued by Medicare since 2008 and has run a business known as Diabetes Alliance since about 2009.
3. Her working life in that period largely involved part-time work, including a permanent part-time Clinical Nurse Consultant - Diabetes Educator role at the Sydney Adventist Hospital for about 19 years, and a home-visit immunology patient support program and nurse injection education program with Janssen Pharmaceuticals for three years between 2018 and 2021.
4. We observe that a nurse educator's role typically involves a higher level of autonomy and a lower level of supervision than other nursing positions. That observation is based on the intrinsic nature of the work, and the fact that Ms Cameron was providing services of that nature to several different medical services in the same period. As noted below, some of the identified problems Ms Cameron exhibited became apparent when she experienced significant personal stressors or when she was required to work in close contact with other medical professionals, such as in a rural clinical setting. Moreover, an independent role of that kind requires clear record-keeping to ensure the quality and continuity of patient care and engagement with other professionals across a range of settings. There was no material in evidence to allow the Tribunal to evaluate her record-keeping, but if her written evidence submissions reflected her general approach to record-keeping, we would have significant concerns about how patient care might be affected.
5. Ultimately, given our findings, this issue does not arise for present consideration; however, in the event that Ms Cameron seeks to have her registration restored at some later date, it would be prudent to provide close supervision of this aspect of her work.

1. About thirty years ago, Ms Cameron suffered from post-natal depression after the birth of one of her children. For a period of about five years, she was prescribed medication which is commonly prescribed for epilepsy and, more relevantly, as a mood stabiliser.
2. In about 2010 or 2011, Ms Cameron's marriage broke down, and in 2014, she was divorced from her then-husband. Ms Cameron reported to the s 150 Hearing that she had been subject to significant physical violence from her former husband and that, when he had been unfaithful, he had told her she was "nuts" and arranged for her to attend a private psychiatrist (whose name she cannot recall) who diagnosed her with "Othello syndrome" after she attended sessions where her then-husband was present. Ms Cameron gave no explanation as to why, given her training and experience as a registered nurse, she did not insist on seeing the psychiatrist in the absence of her husband and on maintaining the confidentiality of her psychiatric care. Ms Cameron stated only that she felt "in her gut" that something was "strange" about her husband attending the sessions with her and insisting throughout that he had not been unfaithful, but did not otherwise show insight into the matter. Ms Cameron's only positive action regarding what was clearly an unacceptable arrangement was to go and see the psychiatrist after the divorce and convince him to "reverse" the diagnosis. No independent evidence was given concerning this diagnosis or its reversal.
3. Ms Cameron also told the s 150 Hearing that she had a psychologist to assist her emotional wellbeing while going through the divorce, which she described as being "very, very traumatic". Ms Cameron told the s 150 Hearing that the psychologist was wonderful and had "backed me up". Subsequently, Ms Cameron told the s 150 Hearing that this therapeutic relationship transformed into a personal friendship and that she had gone away on holiday with the psychologist.
4. In about 2015 or 2016, Ms Cameron received a breast cancer diagnosis for which she received multi-modal treatment. Having regard to her career history, it appears she was required to take significant time away from her work as part of her recovery.
5. As we note above, after the hearing concluded, Ms Cameron was granted leave to tender evidence concerning another psychiatric admission which had not been disclosed to the Council in correspondence or during the s 150 Hearing or to Dr Keller or to her treating general practitioner. Ms Cameron had applied for a summons requiring Royal North Shore Hospital (RNSH) to produce documents; however, that summons was not returnable until after the conclusion of the hearing.
6. The details of Ms Cameron's admission or interactions with the RNSH Mental Health Unit remain unclear because Ms Cameron did not file and serve any evidence produced by RNSH responsive to the summons. The only fact that the Tribunal has been able to establish is that, in 2015, police appear to have referred Ms Cameron to the RNSH Mental Health Unit for assessment after she reported a break-in at a unit in which she was living at the time. It appears that she was assessed in 2015 at RNSH and found to be suffering from delusions. This is gleaned from Ms Cameron's written submissions, part of which we have extracted here:

"... Rather than properly investigate criminal conduct, authorities divert the matter into psychiatric characterisation, thereby misusing medical power to defeat property rights, bodily autonomy and legal standing, in breach of conscience and fiduciary obligation.

Prior to my occupation at that location, a neighbouring resident suffered a serious theft and was admitted to RNSH in shock. A police officer resided on site at the time. Multiple thefts and incursions occurred in the building and garage. My door lock had been physically destroyed. Notwithstanding this objective evidence, RNSH mental health staff, without disclosure to me and/or lawful process, characterised my reports as delusional. This occurred the same year as a NSW Health staff member won a NSW Premiers award in my business name which RNSH staff failed to disclose.

Dr Turner's 2010 and 2015 notes contain statements I say are false, unsupported and misleading, including alleged self-diagnosis of psychosis, alleged family contact, and alleged acceptance of psychiatric labels. No lawful diagnosis exists. No contemporaneous corroboration exists. No GP continuity record supports any such condition. ...

The creation and later use of such disputed clinical entries to support coercive regulatory action constitutes:

● breach of medical fiduciary duty,

● constructive fraud

● abuse of position,

● reliance on tainted trust property."

1. It is not the purpose of these proceedings to make findings about whether an incident occurred and or the mental health assessment of Ms Cameron conducted by RNSH in 2015. Ms Cameron has not sought to tender any evidence on this and has instead provided only submissions. We were invited by the Council to make a Jones v Dunkel ruling, but we have declined to do so, given that these proceedings are protective rather than adversarial. However, what is clear is that Ms Cameron appears to have exhibited behaviours that suggested mental impairment, including delusions, in 2015 and that the police referral of Ms Cameron for assessment in 2015 appears to have been similar to the police referral for Ms Cameron that occurred in November 2024.
2. We further note that Ms Cameron, in her submissions, refers to notes prepared by a psychiatrist, Dr Turner, in 2015 as well as in 2010. The Tribunal was not provided with any information from either party regarding Ms Cameron's 2010 consultation with Dr Turner, and the circumstances of that consultation are unclear.
3. The relevance of the 2010 and 2015 events to the Tribunal's current task is that it appears Ms Cameron did not disclose to the s 150 Hearing that she had attended on Dr Turner in 2010 and 2015, as she has now submitted. At the s 150 Hearing, Ms Cameron was asked whether she had ever had any concern or reason to seek treatment for her emotional well-being, and her only answer was that she sought some support when she was undergoing her divorce in 2014. While a mental health assessment referred by police may not have been something which Ms Cameron considered as something which counted as having a concern or reason to seek treatment - she clearly disagrees with the assessment of delusion in 2015, Ms Cameron's failure to disclose the 2015 mental health assessment and her 2010 attendance on Dr Turner until the Tribunal proceedings is consistent with Dr Keller's findings that Ms Cameron exhibited deficits in both insight and judgment.
4. Ms Cameron's relevant personal history reveals that she has previously been considered to have suffered from a delusional disorder, and that she has little insight into the likelihood that she experienced impairment as a result. That is entirely consistent with her response to being paid incorrectly, Dr Keller's diagnosis and her presentation to the Tribunal, including the totality of her written evidence and submissions.

Dismissal from Janssen Pharmaceuticals, February 2021

1. In January or February 2021, Ms Cameron was dismissed from her role with Janssen Pharmaceuticals. The Tribunal has two versions from Ms Cameron of how she was dismissed.

(1) The first is contained in a summary from Dr Keller's report. which is as follows:

"Ms Cameron described several roles in nursing as described above. She noted that she had worked for Janssen during the pandemic. She stated that, 'I got in trouble for telling a patient not to take a vaccine ... she asked me if there was anything in the (COVID vaccine) ... she had a condition that made her immunocompromised ... I told her there was a problem with blood clots from the COVID vaccine ... I felt I had a duty of care to tell her, but she reported it to Janssen and I was dismissed'."

(2) The second version was provided by Ms Cameron when she asked about her dismissal from Janssen in cross-examination:

"Q: And the last question I had around your CV was the circumstances in which you left Janssen Pharmaceuticals. Now, Dr Keller has given some evidence that you were fired or asked to leave Janssen. Can you explain to the tribunal what happened?

A: Yes, and it's interesting because some solicitors have said, Why haven't you taken action? But I'm not generally a litigative person. The only reason why I have taken up this is because I was challenged not the other way around. So basically, I could have taken legal action against Janssen. So, I had a patient who was a paramedic, and she'd done it before. She would ring and ask and ask, and she said, "Is there any problems, is there any problems with the COVID vaccine?" Now, I was well aware of lots of reports, but they were not validated. However, something had come up that was scientifically validated. And I was put through university, Sydney University School of Pharmacology, by Glaxo when I worked for them. Legally, as a nurse, if you know of any research, you have to tell them. So there was clear evidence of blood clotting with a doctor who died in the US. It was validated with proper autopsies and that type of thing. So I had a legal responsibility to tell her that. There had also been another report that I said, Look, I don't think this is true, but certainly that one was true. Within six months, in fact, the ambulance did publish some sort of data saying that blood clotting is an issue. But at that time, in January or February of 2021, the pharmaceutical industry certainly wasn't acknowledging it, but it actually was published in the US. So I have cause that I could take legal action against them because, by law, I have a clinical responsibility. If I know of a side effect, particularly this lady was on immunosuppressants, they are very high risk. very, very high risk of COVID and everything, but you do have to tell people if you know there are side effects, and that was one particular side effect that's known, that's now better known.

Q: Did you consider referring her to her GP to discuss her?

A: I kept telling her ring her doctor, but she kept at me, and legally it's very difficult when they ask and ask, and I don't know why she was really so adamant to ask me when I kept saying, Please, talk to your doctors, talk to your people, whoever.

Q: Sorry. Do you understand how it came? Did she make a complaint to Janssen?

A: Yes, she made a complaint, and I've been told I could take legal action, but I've not done that. I prefer to leave the past in the past. Because of the published research that's now well known, even at the time, it was not. But, yeah, I had a legal duty of care, and that has been drummed into me as a nurse if you know there's a problem. Particularly, I had to do annual education with Johnson & Johnson, because Johnson is part of Johnson & Johnson. I was flown to Melbourne every year to do education down there, because the data I was collecting was actually collected for Adelaide University. So we were actually doing proper research data collection. So I did have a legal duty of care, and there were actually, at the time, many deaths listed on VAERS. I was aware of many deaths from clotting, but they are not validated. This was."

1. Ms Cameron's evidence in cross-examination on this topic is concerning; simply being badgered by a patient was enough for Ms Cameron to overlook the most appropriate course of conduct with respect to a patient who had queried a treatment. The appropriate course, as the cross-examiner put to Ms Cameron, was to refer the patient to her treating general practitioner, who would have been in the best position to advise her on her particular health issues.
2. The timing of when Ms Cameron advised the patient is a matter of some concern: according to the Therapeutic Goods Administration media release, 'TGA provisionally approves AstraZeneca COVID-19 vaccine for use in Australia', accessed 4 March 2026, it provisionally approved AstraZeneca's viral vector vaccine, the earliest of the vaccines available in Australia to address that virus, for vaccination of individuals aged 18 years and older on 15 February 2021 with the first people in Australia received that vaccine in March 2021. That means Ms Cameron was providing information about a vaccine that had not yet been released in Australia and would not be available for several weeks; accordingly, it is unclear why she felt "legally" bound to offer such advice when there was no possibility the patient would be vaccinated imminently. It also appears to have been widely outside the scope of clinical practice for Ms Cameron in her role with Janssen. The fact that she was unable to identify this as an issue gives the Tribunal deep concern about her ability to function safely in clinical practice for her patients.
3. As noted above, Standard for Practice 1 is that a registered nurse "[t]hinks critically and analyses nursing practice." Under that aggregate standard is the following:

"1.1 The RN accesses, analyses, and uses the best available evidence, that includes research findings, for safe, quality practice"

1. On the bare facts as described by Ms Cameron, telling an immunocompromised person about a case of blood clots associated with the Covid 19 vaccine and apparently failing to weigh up the risks to that person of not having the vaccine, falls below the first of the Standards for Practice. It is not the duty of a registered nurse to tell patients solely about side effects; their analysis is critical. A registered nurse in Ms Cameron's position needed to consider the complexities of the individual patient and help them understand the risks and benefits of a treatment or preventive treatment, such as a vaccine.
2. We note Dr Keller's evidence, given in cross-examination, that Ms Cameron's ill-thought-out, and likely incorrect, advice to the patient constituted one example where Ms Cameron's fixed beliefs and misunderstanding of her role, likely arising from her impairment, created a risk of harm to an individual person.
3. In her answers concerning this incident, as given to both Dr Keller and under cross-examination, Ms Cameron did not exhibit any reflection on the potential harm she may have caused the patient under her care who was making that inquiry. While she was able to identify that the patient, as a person who was immunocompromised, was at "very, very high risk of COVID and everything", on Ms Cameron's account, her focus was not the patient's safety but on a misconceived understanding of her legal obligations and her rights as an employee of Janssen.
4. We have serious concerns for patient safety arising from the incident itself and Ms Cameron's lack of reflection on the possible impacts of her communication with the patient. In our view, Ms Cameron would first need to receive treatment and education to address her lack of understanding of her role, her lack of insight, and her lack of prioritisation of patient safety before it would be safe for her to be allowed to practice as a registered nurse.

Ms Cameron's employment with the Far West Local Health District

1. The voluntary notification which prompted the Council to convene the s 150 Hearing and the orders giving rise to this external appeal came from the Chief Executive of the Far West Local Health District (FWLHD) and was made on 29 November 2024.
2. The notification was expressed to be made pursuant to s 144(d) of the National Law on the basis that Ms Cameron, as a registered health practitioner, may have an impairment. Under that provision of the National Law, the notification is considered a "complaint"; however, that word does not properly express the work the Tribunal, or the Council at first instance, must undertake. Therefore, we have instead referred to the document as a notification.
3. The background to the notification was that, in about 2023, Ms Cameron was engaged to carry out work as a diabetes educator based at Balranald Hospital. Ms Cameron had been engaged under two consecutive temporary employment contracts from late August to mid-December 2023. Thereafter, a dispute between Ms Cameron and the FWLHD arose over underpayment of wages that took most of a year to resolve.
4. According to the notification, the Chief Executive and other senior staff at FWLHD came to have concerns about Ms Cameron's mental state after receiving an email from her dated 20 September 2024. A copy of the email was attached to the notification. Attempts have been made elsewhere to summarise this email due to its length, but we consider it necessary to set it out in full and with its original emphasis and spelling, save for the removal of staff names, as follows.

"Dear [M...]

Regarding: - Therese Cameron underpayment of salary in breach of Industrial Relations Laws.

It was wonderful to meet you when I was living in Balranald and working for NSW Health.

As you are aware NSW Health underpaid me. You may not be aware Industrial Relations Manager [...] initially offered payment of my full legal entitlement of $5,400.00 if I signed a non-disclosure agreement. On 16th September 2024 she offered a payment of less than $2,000.00, which is less than my legal entitlement under Industrial Relations Laws.

The following information relates to Balranald Health Services Manager, and NSW Nursing and Midwives Union Board Member [M... S...], who it is my understanding is currently on "leave" along with her personal assistant, pending financial and other investigations.

You might remember the last time we spoke I commented that somebody had tried to enter my nurses' quarters late at night just after I flushed the bathroom toilet. It is my recollection that you took a sharp intake of breath, (gasped) and you offered to move me out of the Balranald Nurses Quarters

You sounded concerned for my safety, and I sincerely thank you.

As discussed with you, during my last two weeks at Balranald, I noticed my nurses' quarters door was inexplicably not closing properly. It would "appear" to have locked shut, when in fact it was only closed.

I am not privy to the reason as to why the agency nurse from Kenya took up arms by way of a knife, and threatened to kill anybody who came near her; however, I'd like to bring to your attention to the following.

On the same evening that someone tried to enter my nurses' quarters late at night, I had an instance of someone possibly spiking my drink at the RSL Club. I did NOT drink that glass of wine. I was sitting with nurse educator [...] and reported to him that my drink started fizzing, after an older lady moved my glass forward, with her hand cupped. It was a flat white.

This was the second occasion of possible spiking of my wine at the same RSL Club that I last saw you. Please be aware on return to Sydney I put in a police report about these two incidences of possible spiking of my wine at the Balranald RSL Club. I'm not the only one making these allegations.

Why I'm bringing this to your attention is that a local resident who owned the florist shop died at the RSL club one month and one day after the first time I had the possible incident of my drink being spiked. She apparently walked out of the club, projectile vomited at the front door and dropped dead.

[...] was approximately seven years younger than me and apparently had no cardiac history. Projectile vomiting is not a symptom of cardiac arrest. According to the obituary she died at the hospital, which is not true, she died at the RSL.

As [M...] was allegedly at the Balranald RSL Club, she apparently commenced the unsuccessful resuscitation. Apparently when the ambulance got to the Balranald's Hospital [M...] allegedly stood down the nurses on night duty and would not permit them to assist with the resuscitation.

According to both nurses on duty, neither of them had been to the annual races that day, neither of them had been to the RSL club and neither of them had been drinking alcohol.

[M...'s] Sydney friend, who was - they claim - in the casualty was allegedly pulling things out of the casualty cupboards in a way that indicated she was drunk. If this claim is true, it is a serious breach of patient privacy, professional conduct and NSW Health policy, that a registered nurse, not known to local staff, was apparently "assisting" [M...] with a resuscitation when apparently in a drunken state.

The night duty senior casualty nurse on duty, [...] alleged that [M...] allocated too many tasks to the younger of the two paramedics in attendance. [...] alleged four tasks were given to the young Paramedic including documentation of medications given, which [...] said was too much for one person. In the interim RN [...], with years of nursing and management experience was allegedly only permitted to watch.

I have not come forward with this information previously, as I witnessed the manner in which [M...] treated anyone who crossed her. Indeed, I have been subject to cyberbullying when at NSW Health and it cannot be ruled out that [M...] [S...] was the culprit, and it is my understanding that email irregularities are part of the current investigation into [M...] [S...] RN.

The RN [...] specifically states she did not wish to be subject to untoward behaviour during the last six months of her career, and she is now retired.

Case in point being NSW Health transportation officer [...], who claims that - not long after falling out with [M...] - he was sent in to get clothes and belongings out of the nurses' quarters. [...] claims he was not informed that there was a Kenyan nurse in the house armed with a knife, threatening to kill anybody who came near her.

It is my understanding the local on-call NSW Mental Health team, who are trained in deescalating dangerous behaviour, were NOT contacted by [M...] [S...] regarding the issue of an NSW Health staff member in NSW Health staff quarters brandishing a knife and threatening to kill anybody who came near her.

I have spoken to another woman who claims her drink was spiked at the local RSL Club. She says she was "off her face" and remembers nothing. Her friends apparently did video this incident and showed her. She is very embarrassed and reports she is aware of a third individual where the woman's husband became excitingly concerned and how "drunk" his wife was and checked her bill to find she only had two drinks.

She reported that to me that she believes the individual responsible for spiking her drink was dating [M...] [S...]. This is the same individual that served me my drink the first time I had an incident where I believe my drink was spiked. Directly after the death of the local florist at the RSL club, [M...] apparently stopped dating the fellow that worked at the RSL club and started dating a local police officer.

While initially police treated my report with disdain and reported me to Canterbury Mental Health Unit, staff at the unit back right off when I reported there is a coroner's case regarding a woman who dropped dead at the door of the RSL Club.

I pointed this out after a during and after an initial and only interview by staff at the Mental Health Centre. That interview was with a nurse and not the psychiatrist that had been offered. I am asking for full investigation into the nurse at Canterbury Hospital when interviewed me on 28th December 2023, claiming she is a psychiatric nurse.

I recognise her as a diabetes nurse educator from my conferences, either that or it was her twin who interviewed me. That diabetes nurse is currently on extended leave.

Whoever it was that interviewed me I am asking that you ensure a review of her report on our interview is investigated. I'm asking for a full investigation into her possibly falsifying her qualifications to me and saying she is as a mental health nurse, when to the best of my understanding, she's actually a Diabetes Nurse Educator. I'm asking you to validate who it was who interviewed me.

Whoever it was, as far as I can tell they documented false and misleading information about me and the case, as I was phoned a second time for an extra interview, when she was given clear evidence there was a coroner's case in progress for a suspicious death at the same location that I'm claiming I had issues with drink spiking.

If I'm correct and she is a diabetes nurse educator and not a psychiatric nurse, I am requesting she is reported to APHRA for professional misconduct. Either way, I'm asking for a full investigation into the nurse who conducted my "psychiatric assessment" at Canterbury Hospital and that they are reported to APHRA. Whoever this was appears to have falsified information into my report.

I'm also asking for an investigation as to why the Balranald's maintenance tradesmen [...] was relieved of much of his work and that two men drove five hours each way to Balranald from Broken Hill, (10 hours) to carry out maintenance on the Balranald Health Facility, including the Nurses quarters. It appears they may have accidentally readjusted my nurses' quarters in a way that means it did no longer locked shut when it closed.

Thank you for investigating these issues.

Could you please bring to the above to the attention of Industrial Relations Manager, Ms [...]

Ensure she is aware that her most recent offer of less than two thousand, without a non-disclosure agreement makes her previous offer look most questionable and like possible "back-mail". Noting that numerous individuals have made serious complaints about [M...] [S...] over an extended period of time Ms [...'s] previous offer constitutes conspiracy to conceal untoward behaviour. This includes violent and intimidating behaviour to the point that she broke a door at the workplace and then, having been directed to write apologies to all involved in that incident apparently failed to comply with the directive by NSW Health to apologise to all staff involved in writing.

Due to the seriousness of the above complaints, I have forwarded this information onto others, including an international group who are addressing systemic international government corruption and collusion with corrupt behaviour by way of not ensuring appropriate legal action is taking against those involved in corruption.

In the interim can you please ensure that Ms [...] updates her offer to me to $5,400.00 as per the original offer as a matter of urgency.

Yours Sincerely,

Therese Cameron, Credentialed Diabetes Educator."

1. The Tribunal considers that, even within the context of a wage dispute between Ms Cameron and FWLHD, the subject matter and expression of the email were sufficiently concerning that notification to the Council of Ms Cameron's possible mental impairment was justified. It was, in our view, the only proper course for the Chief Executive and the contact officer listed in the notification, who is the Executive Director of Nursing (DON), to take. That is particularly so, given the content of the communication and the obligations of the DON, as a nurse, under cl 7.1(e) of the Code of Conduct for Nurses, Nursing and Midwifery Board of Australia, 2018 (updated 2022). We note that Ms Cameron refers to the Code of Conduct in some parts of her written submissions and in her evidence, and therefore must be aware of its tenets.
2. The notification expressed concern that Ms Cameron had become fixated on an underpayment issue, was claiming that she was being blackmailed (Ms Cameron clarified in the hearing that this was in relation to being offered a settlement subject to a deed of release), was alleging that her emails were being accessed and deleted by other staff (an allegation which she described as being subjected to cyberbullying), alleging that staff from the FWLHD were being impersonated, that her drinks were being spiked at the local hotel, that staff had been involved in inappropriate care of a patient, and that the staff accommodation provided as part of her contract was unsafe, including that the door had been tampered with.
3. In May 2025, after receiving the written reasons of the Council from the s 150 Hearing, Ms Cameron advised it that she had referred the notification letter to NSW Police on the basis, as alleged by Ms Cameron, of "fraud and make false documents", and to the Health Care Complaints Commission[Ex R11]. Ms Cameron provided the front page of her copy of the notification letter, which included the words "Fiction-Grammar", "Fraudulent-Statements" and "Fraudulent-Documents". Ms Cameron did not explain what she intended by including the document altered in this matter. The fact that she has asserted, seemingly without any basis, that the notification was in any way fictional or fraudulent is consistent with other of her written materials, and the expert opinion, all of which point to the likelihood that she is currently suffering from an impairment.
4. At the hearing, Ms Cameron continued to prosecute each of these matters and responded to those points in her evidence. Therefore, we have addressed each of the most significant issues in turn.

1. At, or towards the end of, her contracted engagement with FWLHD, Ms Cameron stated that she realised that she had been paid at a rate lower than the contract provided. There was no explanation provided by Ms Cameron as to why she only became aware of being underpaid at the end of her contract; the payslip in evidence before the Tribunal records, in two places, that she was being paid at the rate associated with the classification "Clinical Nurse Specialist Gde 2 Year 1" and not, as her contract apparently provided, for a "Clinical Nurse Specialist Gde 2, Year 2 and Thereafter".
2. The letter of appointment from FWLHD, dated 23 August 2023, also specifies that she is to be employed at the classification of Clinical Nurse Specialist Gde 2, Year 1. Those classifications and the associated wage rates commencing on 1 July 2023 are set out in the Public Health System Nurses' and Midwives' (State) Award 2023, as varied from time to time. We observed there was a general lack of attention to detail regarding her grade in her later correspondence on the underpayment issue, in which she referred to being paid as a "CNC Level 1"; whereas, according to the award, as well as Ms Cameron's payslips and other correspondence, CNC Level 1 was never part of her classification description.
3. In an email forwarded to the electorate office of the Hon Ryan Park, Minister for Health, in December 2024, [Ex R9, p 235] Ms Cameron asserted that the difference in the miscalculation of her wage amounted to about $10 per hour. She wrote:

"Here is the proof of wage theft, they continue to be in breach of industrial relations laws by writing up an unlawful contract to pay me CNS level 2 (they paid me level 1, first year) when I should have been paid CNC Level 2, which is a $10 per hour difference. It is like paying a Qantas pilot at captain level, with years of experience, a much lower pay rate when he/she returns to Qantas after working away, because it suits them, not because it is lawful."

1. That assertion is not correct. The wage tables in the award provide that the weekly (38-hour) wage for a Clinical Nurse Specialist, Grade 2, Year 1, is $2,107.10. That weekly rate equates with an hourly rate of $55.45. This is the same rate shown on Ms Cameron's last payslip for the period ending 17 December 2023. The weekly wage rate (again, based on a 38-hour week) for a Clinical Nurse Specialist, Grade 2, Second Year and Thereafter, is $2,176.30. That equates to an hourly rate of $57.27. The difference between the hourly rate Ms Cameron was paid and the hourly rate she was contractually entitled to was $1.82, not $10 per hour as Ms Cameron contended.
2. In April 2024, the Chief Executive of FWLHD corresponded to Ms Cameron's demand for a pay correction, in part seeking evidence that she met the qualification level suitable for a Clinical Nurse Specialist, Grade 2, Second Year and Thereafter. In his letter, the Chief Executive states that the only evidence of Ms Cameron's experience on file was a statutory declaration, which, he advised, was insufficient. The agency that handled her engagement with Ms Cameron states that it provided a statement of service to FWLHD in August 2023, before she commenced work; that statement of service document was not in evidence before the Tribunal. There was no direct evidence of what Ms Cameron actually provided at the date of her engagement or at any later time; there is a reference to Ms Cameron having provided the material under a cover letter dated 17 May 2024.
3. We note that the day prior to that second provision of information, NSW Health sent a letter to Ms Cameron notifying her to cease and desist in the repeated harassment of staff. [Ex R18 Tab 5.53 of R Bundle]. Ms Cameron refers to this notice in her submissions, yet makes no connection between it and the terms proposed to her under the draft deed, which include a non-disparagement clause.
4. In any event, by September 2024, Ms Cameron had received the back pay to which she was entitled, amounting to $1,004.
5. It does not appear that Ms Cameron was entitled to any higher sum based on the calculations referred to in the award. Despite this, she continued to insist that she was entitled to be paid $5,400.
6. In her reflection dated 5 January 2025, provided to the s 150 Hearing, Ms Cameron continued to assert her entitlement to $5,400 in the following terms:

"The Nurses and Midwives Council has been provided proof of Wage Theft, which is criminal behaviour, and proof I was offered $5,400 if I signed a non-disclosure agreement. I was underpaid for the work I performed, then told I could receive those monies if I signed an NDA. I am still waiting for payment of my wages owed."

1. Of course, by 5 January 2025, Ms Cameron had been paid the wages that she was owed. She had received the $1,004 in September 2024.
2. Nonetheless, as late as 24 March 2025, Ms Cameron was still sending emails in which she claimed to be entitled to $5,400. It was on that date that she sent an email to the Council asking for its support in recovering money from NSW Health.
3. At the s 150 Hearing on 31 March 2025, Ms Cameron conceded that the underpayment of her wages had resolved. However, by the time she applied to the Tribunal, Ms Cameron continued to assert that "wage theft" had been "validated" by the NSW Premier's Department and that she had been offered $5,400 to sign a deed, which she did not accept because it was an attempt at coercion with an offer of money that amounted to "attempted bribery". The letter from the NSW Premier's Department was in evidence; that letter decidedly does not validate Ms Cameron's position that she was entitled to $5,400.
4. Despite her concession at the s 150 Hearing, Ms Cameron stated that on 12 April 2025 she "opened a case with ICAC regarding wage theft, fraudulent documents and coercion to sign the deed of release".
5. The persistence with which Ms Cameron has maintained the allegation of "wage theft" and the fixed assertion, by her, that she is owed an amount of $5,400 suggest that she is prone to becoming fixed in her ideas, including incorrect ideas. That may be the stickiness to which Dr Naidoo refers in his report and is consistent with Dr Keller's findings, which we discuss below.

1. In July 2024, NSW Health provided Ms Cameron with a draft deed of release which, subject to terms, would have meant she would have been paid $5,400. That deed is seemingly responsive to the letter of demand sent on Ms Cameron's behalf.
2. The evidence before the Tribunal shows that, in June 2024, and without providing any details of the calculations used to arrive at the figure, Ms Cameron made a demand to FWLHD to pay her the sum of $5,400. That figure is grossly more than any underpayment to which she was otherwise entitled. In fact, to be underpaid by that amount, Ms Cameron would have had to have worked 2,967 hours in a period of four months. The evidence suggests she worked 32 hours per week, which, assuming she worked each day of both eight-week contracts, brings her total working hours to 512 hours.
3. The $5,400 demand was made on Ms Cameron's behalf by a body called the Professional Nurses Association of Australia, which is not a registered industrial organisation and is consequently not subject to the internal and statutory governance required of registered industrial organisations. It appears that Ms Cameron was poorly served by that body - the most basic calculations were not performed in accordance with the award, and Ms Cameron does not appear to have been advised of the extent of her entitlements before a letter of demand was sent on her behalf. Those failures appear to have given Ms Cameron a false expectation of a much greater sum of money than she was ever entitled to receive and created a wrongly based suspicion that her former employer was acting in an underhanded manner, from which she was unshaken even when this same organisation finally informed her that she had no further contractual entitlement. The significance of this cannot be overstated, given that, in the evidence before us, Ms Cameron has insisted that the only reason she pursued the allegations against FWLHD was that she had not been paid $5,400, as she believed she was entitled to receive.
4. The notification letter refers to allegations made by Ms Cameron of blackmail, which relate to FWLHD or NSW Health providing Ms Cameron with the draft deed of release. In cross-examination, Ms Cameron was asked whether the word "blackmail," as used in the notification letter, accurately characterised her allegations. In fact, that word was expressly adopted by Ms Cameron in her email of 20 September 2024. The following passage sets out Ms Cameron's central response at the hearing in the Tribunal:

"A: Okay. Now, as far as the allegations of blackmail, which I've it was the wrong language, although with ChatGPT, when you look at it, They do say coercion. They even use the word extortion. When you offer somebody a non-disclosure agreement for silence...

Q: Okay. You wouldn't use blackmail, you would use coercion or extortion.

A: I think that's... They also came up with the word blackmail as well. So they offered me money, $5,400, which I didn't accept, to sign a non-disclosure agreement. So which page are we looking at?

Q: It's 5 sorry, 478, and what I'm trying to get at with my question, just to be clear, is whether that is a fair summary of your complaints or concerns, and you've explained that the word blackmail is perhaps not quite right, and you? Can use coercion or extortion.

A: And I've got to use... Thank you."

1. There is no direct evidence of how the draft deed was prepared. In any event, it is an incomplete draft with some highlighted sections; it contains six primary clauses and covers less than four pages.
2. A draft deed of this kind is, for lawyers, a tool of negotiation, including as to drafting of the background or context and the operative terms; however, Ms Cameron reacted to the draft in an altogether different way. Having been told that she was entitled to $5,400 in backpay, Ms Cameron says she believed that because the deed included non-disparagement and confidentiality clauses, and because the non-operative recitals contained matters with which she did not agree, that she was being pressured by NSW Health into entering a deed in order to receive money to which she considered she was legally entitled. When asked in cross-examination whether she sought to have the terms of the draft deed amended, she gave the following response:

"Q: Did you try to negotiate that with them?

A: That's up to my union.

Q: And did you ask your union to negotiate about the terms of settlement, given you didn't agree with that part?

A: As far as I know, they did. I don't know what happened, but I didn't end up. No, it's not entirely up to me."

1. What Ms Cameron meant by the statement "its not entirely up to me" was unclear, but it suggests that the body representing her in fact failed to carry out the most basic duty of an agent, which is to act in the best interests of a principal and there was no evidence adduced by Ms Cameron as to what her then representatives actually did in terms of seeking to have the draft deed amended so that she might have put the dispute behind her and receive more than four times the money she was otherwise entitled to receive.
2. It may be, to some limited extent, understandable that had Ms Cameron believed that she had been underpaid by $5,400, then she might have considered that the terms of the deed were more onerous than simply seeking recourse through litigation that she could have pursued. But that is not what Ms Cameron did; instead, she appears to have fixed upon with the idea that the draft deed - presented to her, not for signature but as a draft - was a "fraudulent" document and an attempt to cover up "wages theft" by the management at FWLHD or the NSW Department of Health and that she was being coerced or extorted (the terms she embraced in cross-examination) or blackmailed into silence. In her application to the Tribunal disputing the findings of the Respondent at the s 150 Hearing, Ms Cameron wrote, of the deed:

"Offer of $5,400 and NDA - which I did not accept - evidence was provided, attempted coercion to sign and NOA, with offer of money is attempted bribery. (see evidence attached)."

1. As well as characterising the draft deed as criminal conduct, Ms Cameron also reported the matter to the Independent Commission Against Corruption in NSW (ICAC), having previously referred the matter to the Industrial Relations Commission of NSW, which decided to take no further action regarding the matter. She then received a letter from the NSW Premier's Department in November 2024, which set out the relevant facts and noted that the matter had been resolved and that Ms Cameron had received the wages she was entitled to be paid.
2. In her submissions to the Tribunal, Ms Cameron asserted that the notification provided by FWLHD was, in fact, "retaliatory, following my refusal to sign the non-disclosure agreement regarding wage theft". There is no proper basis for that allegation. The obvious and proper trigger for the notification was Ms Cameron's email of 20 September 2024, which we have extracted in full at paragraph [48] above, which, as we have noted above, tended to suggest that Ms Cameron was suffering from psychiatric impairment.
3. Ms Cameron, however, did carry out a retaliatory campaign against at least three senior staff members from FWLHD. This included an email sent on 9 December 2024 to the HCCC, copied to the Respondent, Ms Cameron's local parliamentarian, and the administration inbox for "AFL Solicitors". In that email, Ms Cameron criticised the conduct of the DON, who, as we note above, was listed as the contact person in the notification letter, stating, in part (with original emphasis) that:

"[the DON] has shown gross professional misconduct by failing to contact me about this case which was sent to FW NSW Health on 20 September 2024.

She has engaged in "thwarting the course of justice" and professional misconduct [i]n a coroner's case, by failing to ensure all evidence was reviewed and reviewed by someone who is independent ...

Instead of investigating this case [the DON] is engaging in "vindictive reporting" and "Definition of Character" [as written] of me by way of reporting me to the NMC rather than contacting me to find out what evidence I have regarding my allegations.

Please see the information below regarding the Proven Case of "Wage Theft; which appears to have occurred in collusion with [the DON], [two other staff]. Far West NSW Health Still owes me $4,400 in back pay as per evidence provided. This goes towards my complaint that [the DON] is not an appropriate person to hold the position she holds in NSW Health.

Please ensure all evidence is kept, while some evidence is not all related to patient health, it is of grave concern that someone being tasked with being the head of Far West NSW Health is acting in this manner.

I WILL PROVIDE MORE INFORMATION in DUE COURSE

URGENT: - In the interim, am asking you that you ensure that [the DON] s not permitted to visit the township of Balranald as this could possibly "intimidate" those who made Complaints about [Ms Cameron's former immediate manager], or those involved in the complaint I made about [Ms Cameron's former immediate manager], which - as stated, did become a coroners case."

1. Pausing there, the Tribunal observes the aggressive tone, the muddled nature of the submission and the bizarre request to the HCCC that it prevent the DON from entering a township which was within her area of responsibility. In other parts of her materials, Ms Cameron alleges that someone other than the DON must have prepared the notification, largely because the notification is not written in a consistent style with other material prepared by the DON and that it was "inconceivable" that the DON would have the time or knowledge to prepare it. The DON is not the signatory to the notification, which, as we noted above, is signed by the Chief Executive.
2. Both Ms Cameron's email and her later allegations regarding authorship of the notification exhibit a conspiratorial and paranoid approach, which appears to conform to Dr Keller's observations and opinions of Ms Cameron's likely impairment.
3. The Code of Conduct, cl 1.2, requires that nurses practice ethically and not conduct themselves in a manner that could damage the reputation of the profession. Cl 1.2(d) specifically provides that Nurses must understand that the making of frivolous or vexatious complaints may be viewed as unprofessional conduct or professional misconduct. Our role here is not to determine misconduct, but to consider whether conditions should be placed on Ms Cameron's registration for the protection of the public or otherwise where it would be in the public interest to do so. The Code of Conduct is nonetheless informative for our consideration of what is an unacceptable risk to the public interest. Acting in a manner that might damage the profession's reputation poses an obvious risk to the public interest.
4. In reviewing the draft deed, it contains the following:

(1) First, the matters recited under the heading "Background" are non-operative clauses which, aside from some definitions, only set out the context for the terms of the deed. It was always open to Ms Cameron to seek to amend or re-draft those clauses to reflect her understanding of the background to settlement. Given that she was represented at the time, this could not have been a difficult or onerous task.

(2) Second, the operative clauses of the draft deed may be summarised as follows:

(a) A mutual release to each party of any claims they may have against each other arising from the dispute which is defined being in relation to Ms Cameron's claim to be paid at a particular level of a Clinical Nurse Consultant (we note in passing, the draft deed also mis-states the classification system and contained various grammatical errors, consistent with the document being a draft). Accordingly, the only aspect of her employment that is subject to the deed is the underpayment issue;

(b) A bar to proceedings clause, again, mutual, which means that the parties can rely on the deed if a claim is made on the same basis in a court;

(c) A clause for the payment of a settlement amount by the employer to Ms Cameron, providing an executed counterpart of the deed and agreement by Ms Cameron to make no further claims (not defined, therefore, only in relation to the dispute) against the employer;

(d) An undertaking as to confidentiality over the settlement negotiations leading to execution of the deed. We observe that this is not a general non-disclosure and only relates to negotiations concerning the terms of the settlement;

(e) A wide-ranging non-disparagement clause, imposed only on Ms Cameron. We observe that this may have been considered necessary where the employer had previously sent a notice to Ms Cameron to cease and desist her harassment of its staff; and

(f) A general terms clause covering matters such as governing law, date of effect, variation, counterparts, severability and an entire agreement sub-clause.

1. Ms Cameron's attitude toward the draft deed and NSW Health's proposal to pay her demand, subject to entering a deed, is both strange and disproportionate. She did not countenance the fact that the sum offered to be paid under the deed was well more than any underpayment of wages she had suffered. She failed to consider that the employer may have sought an agreement from her regarding non-disparagement, given her earlier conduct, which it considered to be harassment of its staff. She also failed to consider seeking an amendment to the proposed deed terms before executing it - a course that was always available to her. Most concerningly, rather than contemplating other, more innocent explanations for why such a deed was offered or seeking to re-draft the offending terms, Ms Cameron almost immediately moved to characterise NSW Health's presentation of the draft deed and acceptance of her demand, subject to the deed, as conduct of a criminal nature. We consider that Ms Cameron's reaction to the draft deed of release is consistent with Dr Keller's findings that Ms Cameron is impaired.

1. Among the several matters contained in her email of 20 September 2024 was an allegation by Ms Cameron that while employed by FWLHD, she was the subject of cyberbullying because, she asserted, her emails were accessed and deleted by other staff.
2. That allegation was not a new one. Before the Tribunal, Ms Cameron put forward a series of emails which she relied upon to demonstrate that emails she had attempted to send in the days before her departure from Balranald had been removed from her sent items folder and then purged from her account and had also been removed from the inboxes of the email recipients. We have looked at each of the emails relied upon by Ms Cameron in some depth. None of the material establishes what she contends.
3. Ms Cameron submitted that the email correspondence she had with the IT department "validated" her position that she was being cyberbullied. Having looked at that material closely, we can find no such validation. What is apparent is that in her final days at Balranald, Ms Cameron had some difficulty with emails she thought she had sent. Specifically, her email dated 15 December 2023 to the IT officer states that she had emailed staff members to ask whether there was anyone she needed to contact in the Balranald region before she left for Sydney. She stated she printed those emails and then found the electronic copies were in her deleted items folder rather than her sent items folder. She then records that the IT officer said the email had been purged, which Ms Cameron understood to involve the message being recalled from the recipients. With respect, if Ms Cameron had been able to locate the email in the deleted items folder, it could not have been purged. Nonetheless, Ms Cameron's email went on to say, with original emphasis:

"I am confident that you will all be able to 'find' who it is that is accessing my email account in a manner designed to 'set-me-up' to look unprofessional and ensure appropriate action proceeds."

1. The issue here is that rather than considering an innocent possibility, Ms Cameron has immediately proceeded to suspect her work colleagues of actively taking steps to tarnish her reputation by manipulating her emails. She does not appear to consider that the problems she experienced may have been caused by her own errors, nor did she appear open to any one of a number of innocent explanations that may have been available. That is particularly concerning when there was no apparent reason given why Ms Cameron, who indicated in the same email that she was completing the last shift of her temporary contract that day, would be the target of cyberbullying. It is unclear how the purging of emails could have made Ms Cameron look unprofessional in any event, as she was not returning.
2. Moreover, we have observed that Ms Cameron appears unusually prone to losing documents, both electronic and hard copy, and being the subject of unexplained "hacking" which suggests that rather than being the victim of cyberbullying, her concerns in this regard, as Dr Keller opines, are manifestations of a likely delusional disorder. By way of example, we note that:

(1) Ms Cameron claimed that in February 2024, she had noticed "an entire box of documents had gone missing from my home".

(2) In an email dated 31 March 2025, leading up to the s 150 Hearing, Ms Cameron stated:

"• In the face of viewing multiple lies and misinformation about myself sent to the Nurses and Midwifery Council and repeated by the NMC and ongoing IT hacking into my home computer I noted one of the NMC investigators worked at the location my daughter was an inpatient.

...

• During the night of Friday 29th someone hacked into my computer and started to try to operate my printer, in a way I found intimidating.

...

• When submitting to the Premiers Office about Wage Theft, my computer would not upload some documents and went off line for 24 hours prior to the closing date I needed to get the documents uploaded."

(3) In an email dated 22 April 2025, Ms Cameron reported that her computer had "crashed" and that all of her back-up documents had "vanished from backup locations".

(4) In an email dated 3 May 2025, Ms Cameron stated in an email that her statement of service from FWLHD had "vanished" from her computer.

(5) In cross-examination, Ms Cameron stated that she had trouble receiving emails from the Tribunal and that:

"...at NCAT they commented on just a computer irregularity with one of my emails, that something happened that was a little strange that they thought was a little odd, that may or may not indicate there's some sort of strange virus in my computer that affected their emails."

Other allegations relating to staff misconduct at FWLHD

1. None of the other allegations made by Ms Cameron in her letter concerning staff misconduct at FWLHD were the subject of convincing evidence. Moreover, as Dr Keller points out, the relevance of establishing whether there was staff misconduct misses the point in assessing whether Ms Cameron is suffering from any impairment. More relevant to that assessment is the way she raises allegations. It is that which, according to his assessment and our own observations, tend to show that Ms Cameron is suffering symptoms of a delusional disorder.
2. In her closing submissions, Ms Cameron, after repeating these other allegations as she had set out in the September 2024 email, stated:

"Ms Cameron: Now, I know I probably shouldn't have written that email of complaint, but when you're going for job after job after job and they're not looking at you, it's like, well, who knows?"

1. If it is the case that Ms Cameron sent the September 2024 email because she was frustrated or was experiencing persecutory delusions as a result of not being selected for positions she had been applying for, then her acknowledged conduct in this regard directly falls well below cl 1.2 of the Code of Conduct, that, as we note at paragraph [15] above, requires that nurses practice ethically and not conduct themselves in a manner that could damage the reputation of the profession.

1. At its highest, the evidence of intruders or door tampering at the nurses' accommodation at Balranald is a daily safety huddle report for 13 December 2023, being a date in the last week of Ms Cameron's employment and the same date as the alleged drink spiking incident, which we describe below. In that report, Ms Cameron has recorded that a person was on the facility grounds at about 3 AM, that night-duty staff had attended, and that a garbage bin had been pulled up against a fence the night before. On that report, the "no" box has been checked against the question "[a]re there any safety threats anticipated in the next 24 hours to Patient/Staff/Workplace." Ms Cameron has signed and dated the report as the person "in charge". Ms Cameron says this was the same date that a person had possibly tried to enter her bedroom. Yet that incident is not recorded in this report. A daily safety huddle report for the day prior is also in evidence and is signed by a person designated as nurse unit manager, though Ms Cameron was listed as an attendee. That report records that a "chair near fence" but otherwise identifies only "heat" as being a safety concern in the next 24 hours.

Drink spiking and reports to police in December 2023

1. Among the several issues narrated by Ms Cameron in the September 2024 email were allegations that on two occasions she had been served spiked drinks by different bar staff outside of work hours, while working in Balranald.
2. On 18 December 2023, shortly after returning home following completion of her contract work in Balranald, Ms Cameron went to Campsie police station. There, she reported to police that someone in Balranald had tried to spike her drink and that there had been two incidents of drink spiking: one in September and the other on the evening of 13 December 2023.
3. We pause to note that 13 December 2023 was a day on which Ms Cameron may have been experiencing significant stress; she had thought that someone was entering her bedroom overnight and that there had been intruders around the staff accommodation where she was staying; this was also the day she was making inquiries of the FWLHD IT staff about her emails disappearing; it was, in fact the last day of her short term contract and therefore she was in the process of finishing and preparing to head back to Sydney.
4. Ms Cameron's presentation at Campsie police station was sufficiently strange for them to refer her to the Canterbury Community Health Centre, which is attached to Canterbury Hospital. She had told police at Campsie that she had tried to report the incident at the Balranald police station, but it had been closed due to the death of a child - an event that one would think required the police station to be fully operational.
5. The assessment and discharge notes of that referral were not available at the time of the s 150 Hearing but were available to Dr Keller and to the Tribunal at the hearing. According to the notes of her attendance on 18 December 2023, the police had considered that Ms Cameron was suffering from paranoia, and Ms Cameron was very upset that the police had referred her for a mental health assessment. The notes record a variety of concerns expressed by Ms Cameron, including that she was subjected to workplace bullying, as well as her denial that she felt she was experiencing any delusions or perceptual disturbances. The assessment of Ms Cameron found no basis on which to detain her involuntarily.
6. However, it is apparent that the staff at Canterbury Community Health considered Ms Cameron may have benefited from further investigation with a psychiatrist. The record of the telephone interview follow-up between a registered nurse and Ms Cameron on 5 January 2024 is as follows (with the meanings of various acronyms being inserted for clarity):

"PC [phone call] to client to offer MOR [Medical Officer Review], answered promptly.

Reported was waken up by ACS's call, however happy to continue to converse.

Reported has been doing well.

As soon as author offered client's MOR, she became agitated and offended.

Stated that 'I don't have any psychiatric issue, there is someone just dropped dead outside of the pub in that area (Broken Hill) that required resuscitation, the problem is that area, I am not the problem'

Advised her that we are offering MOR as we believe it will benefit her, does not imply that she has any psychiatric problem, client stated 'why do you offer me but not anyone else? What did you tell the police?'

Client then stated 'I don't think there will be any benefit for me, I agreed to came the other day, why didn't the psychiatrist see me then?'

Advised her about how ACS operates and told her that she has a right to decline to engage, client still declined to be seen by psychiatrist 'I already came, don't tell me that I don't want to engage'.

Client kept going back to 'there is someone dropped dead, it does not usually happens does it?'

Advised her that ACS will refer her back to her GP."

1. Ms Cameron avoided entirely addressing the fact that she was offered psychiatric review by Canterbury Community Health and declined to take it. Rather, her main focus arising from her attendance concerned the fact that she felt had been treated with disdain by the police and then been assessed by another Diabetes Educator instead of a mental health nurse or psychologist when she attended Canterbury Hospital.
2. In Ms Cameron's document entitled Notice of Further and Better Particulars, she describes her attendance in the following way:

"At Canterbury Hospital, an appointment with a psychologist was booked, but instead a nurse arrived. She looked very similar to one of their Diabetes Educators and even speaks the same language as the person I saw. That Diabetes Educator is not registered with AHPRA under the name her manager provided to me. No one is registered as a nurse under that name."

1. In her September 2024 email, Ms Cameron sought a "full investigation" into Canterbury Hospital's handling of her mental health assessment. Presumably, such an investigation would address Ms Cameron's concern that a Diabetes educator was "claiming to be a psychiatric nurse."
2. At the hearing, this is how Ms Cameron explained her concerns over drink-spiking in the course of cross-examination:

"Ms Cameron: Now, as far as drink spiking goes, I can't prove that. Who can? All I can prove is that I had a weird experience on one night where I was really, really giddy, and when I told my colleagues, they said, 'Oh, well, that's the thing that happens at the RSL club.' Well, you know, the country towns, everybody gossips about everything, but that's what I was told. On the second time when there was a possible drink spiking episode, I can go into the details, but my drink fizzed and it was a white wine and this woman had put her hand over it and it was supposedly a flat white wine and it was fizzing like I couldn't believe. So I felt very uncomfortable and I didn't drink it. I know of a number of people who had drinks and we only know, well, look at Malcolm Fraser. Yeah, so he's not getting caught with his pants down. So basically, drink spiking is not unusual. I had it, in fact, one of my first New Year's Eve parties where my sister was, I had a drink spike, and that was over in Vaucluse. Somebody spiked my orange juice. And I went after an evening shift, and I was drunk as the Lord by 1am. And yeah, I said to me, I'm not drunk. I've only been here. I've only been here an hour. I haven't drunk any alcohol. So it's not... The first I've had previous drinks this thing is not I've spoken to lots of people over drinks spiking. In that instance, I was told by colleagues that it is an issue at that place. I spoke to colleagues who claimed they had had that problem. That's all I can say."

1. Ms Cameron's opinion that another diabetes educator arranged for a mental health assessment of Ms Cameron, impersonating a mental health nurse, for some unknown reason, is peculiar. Her response, excerpted immediately above, was part of a lengthy answer and reflected a confused, rambling thought process. While some of that confusion may be attributable to the stress of the proceedings, it was well outside that which is usually observed by the Tribunal.
2. In the course of his cross-examination, Dr Keller addressed the drink spiking and the Canterbury Community Health assessment in the following way, in further answer to Ms Cameron's request that he provide further evidence for his conclusion:

"Dr Keller: The other delusions that I had used were in the realm of persecutory or paranoid beliefs, and I've referred to them right at the beginning of my evidence today. It relates to the belief that you may have been, your drink was spiked, i.e., that you might have been poisoned deliberately, that you had been... Sorry, I'm just finding my notes. that you had been cyberbullied, that you'd undergone a psychiatric assessment from a diabetes nurse impersonating a psychiatric nurse, so a misidentification delusion potentially. So whilst I accept that all of these could be refuted, they certainly fall within the realm of paranoia, even if they may not meet the threshold for a delusional belief."

1. Dr Keller does not make a definitive diagnosis, nor is it the role of the Tribunal to do so. However, regarding his evidence concerning Ms Cameron's delusional thinking, we accept Dr Keller's evidence. That evidence, together with the fact that her behaviour was sufficiently concerning to police to ask that she attend an assessment, and Ms Cameron's reaction to it, exemplify the type of concerning behaviour that has led us to the conclusion that Ms Cameron should not be permitted to practice as a registered nurse until she has received appropriate treatment and has been further assessed.

1. A persistent issue in Ms Cameron's evidence and submissions was an allegation that her registered business name, Diabetes Alliance, had been used by other medical professionals.
2. We note, from the outset, that the registration of a business name, as opposed to the registration of a trademark, does not give exclusive rights or property to the registrant of any or all of the words registered as a business name, which is clear from s 17 of the Business Names Registration Act 2011 (Cth).
3. Nonetheless, Ms Cameron gave three examples where she said people had deliberately misused her registered business name.

(1) In the first case, Ms Cameron submitted a document tendered by her that proved that in 2015, a doctor received an award for his work in Diabetes Alliance integration work. The document relied upon by Ms Cameron does not say this. Instead, the award was given for the doctor's work with "Diabetes Alliance, Hunter New England Health"; it was not that Diabetes Alliance, Hunter New England Health was a business name, the context suggests that name is one for a diabetes program run by the Hunter New England Local Health District.

(2) In the second case, Ms Cameron relied on various screenshots connected to another person who seems to have worked in a role associated with Diabetes Alliance, Hunter New England Health. That material run by a local health district and not a business.

(3) Third, there was an ASIC search showing that "Diabetes Alliance Program Plus" had been registered as a business name on 14 June 2024. This business name is not "identical or nearly identical" as defined under rules set out in the Business Names Registration (Availability of Names) Determination 2015 (Cth), when compared to Ms Cameron's registered business name.

1. The evidence and submissions on the issue of the misuse by others of her registered business name appear consistent with Dr Keller's diagnosis of delusional disorder which is set out below.

1. Dr Cholakyan is Ms Cameron's general practitioner. He and his now-retired colleague have been Ms Cameron's family doctors for several years. However, we note that, as of December 2023, when Ms Cameron attended Canterbury Community Health, she reported that she had not seen Dr Cholakyan for almost one year.
2. In December 2024, Dr Cholakyan prepared a medical certificate declaring Ms Cameron fit for work, which Ms Cameron tendered as evidence.
3. In giving his evidence under cross-examination, Dr Cholakyan stated that he had prepared the medical certificate based on his expertise and knowledge of Ms Cameron's situation. In answering a question put to him directly by the Tribunal, Dr Cholakyan stated that he issued the certificate based on his general observations, what Ms Cameron had told him, and what was presented before him. He reasonably conceded that he did not have specialist psychiatry training and that he was not qualified to assess psychiatric functioning, overvalued ideas or delusional thinking. He also conceded that it was certainly possible that a patient may appear superficially well while having underlying psychiatric behaviours or beliefs that could impact upon work performance. Finally, Dr Cholakyan conceded that he had not previously conducted a formal assessment of a patient for capacity to practice as a registered nurse under conditions of suspected psychiatric impairment.
4. The Tribunal took Dr Cholakyan to be an experienced and caring general practitioner who was sincerely interested in Ms Cameron's wellbeing and health. He had put in place a mental health plan and referred her to a psychologist.
5. Dr Cholakyan told the Tribunal that he had referred Ms Cameron to the psychologist under a mental health plan on the same date as the medical certificate, being 10 December 2024. That plan had been instituted, Dr Cholakyan told the Tribunal, because Ms Cameron was quite anxious about her daughter's health. He had made a note at the time that she had told him she was anxious because "she was having a dispute with her previous employer regarding unpaid wages, and breach of contract". We note that, by December 2024, Ms Cameron had, in fact, been fully remunerated for her underpaid wages and that it was in December 2024 that she had been referred to the Respondent. Dr Cholakyan cannot be criticised for believing his patient, but it suggests that Ms Cameron's thought process remained fixated on the underpayment issue, which had, by that stage, been resolved months earlier.
6. It appears, however, that Ms Cameron had not implemented that plan since Dr Cholakyan had yet to receive any feedback or correspondence from the psychologist, as is the usual practice. In re-examination, Ms Cameron suggested to Dr Cholakyan that she had seen the psychologist twice under the December 2024 plan. However, as a result of her questions, it seemed that she then accepted that those appointments related to an earlier mental health plan in place in 2011 that had been reviewed in 2012.
7. What we can conclude from Dr Cholakyan's evidence is that:

(1) Ms Cameron has a general practitioner who has attempted to act in her best interests and has a long-established therapeutic relationship with her.

(2) Ms Cameron did not frankly disclose to her long-standing general practitioner that she was facing an inquiry relating to her professional conduct and suspected impairment in December 2024 when she requested that Dr Cholakyan issue her a medical certificate. Rather, she told him that she was anxious because of a contractual or wage dispute with her former employer, for whom she had not worked for a year as of December 2024; and

(3) Ms Cameron has not taken the opportunity provided to her under the mental health plan devised for her in December 2024 by Dr Cholakyan to see an appropriately qualified psychologist. As with her failure to take the medication prescribed by Dr Naidoo, we consider the failure to access the services available to her under the mental health plan to show a lack of insight into her condition and a lack of judgment.

Dr Keller's findings, opinion and recommendations

1. One consequence of the s 150 Hearing was that Ms Cameron was assessed by Dr Adrian Keller, a psychiatrist. Dr Keller's report of 25 May 2025 was tendered by the Respondent. In his report, Dr Keller set out his findings based on the documents provided by the Respondent and his assessment and examination of Ms Cameron, which lasted, on his account, about two hours and on Ms Cameron's account, about 100 minutes.
2. Dr Keller noted that the documents provided to him showed complaints made by Ms Cameron, including underpayment, blackmail, conspiracy to conceal behaviour, drink spiking, drunk staff, cyber bullying, a diabetes nurse impersonating a psychiatric nurse, someone entering her nursing quarters, and the door not locking properly. During the assessment, Ms Cameron repeated her concerns on those topics again to Dr Keller. We have already set out the content of some of those documents elsewhere in these reasons. Nothing in Dr Keller's report showed he had mischaracterised the material with which he had been briefed.
3. As part of the assessment, Dr Keller took a detailed medical, work and family history from Ms Cameron and observed the way in which she presented herself and her history. That included Ms Cameron's early life and education, her career roles, including her dismissal by Janssen, the breakdown of her marriage and the assessment by a psychiatrist whose name she could not recall that she was suffering from "Othello syndrome" which Dr Keller explains as "an eponymous name for the disorder morbid jealousy".
4. The account provided by Ms Cameron concerning morbid jealousy disorder was consistent with the information she provided to the s 150 Hearing. In passing, we note that the details she provided to the Tribunal, Dr Keller and the s 150 panel are highly unusual. In his report, Dr Keller records his exploration of the issue with Ms Cameron in the following terms:

"When I asked what led her to the conclusion of his infidelity, she stated: 'There were tampons missing from our yacht.' To clarify this statement, she said that she suspected that he had been entertaining other women on the vessel. She also stated, 'I found lipstick under one of his collars.' When I asked for clarification, she stated that it was intended as a sign from the other woman to notify Ms Cameron that 'I am here.' She stated that she confronted her husband, and the shirt in question subsequently disappeared.

Ms Cameron stated that between 2010 and 2015 she was having difficulties in her relationship with [her then husband], and he asked her to see a psychiatrist. When asked why she agreed to do this, she stated, 'I had a gut feeling ... this is not right ... he [i.e. the husband] told me I am nuts ... he attended the sessions (with me) to control the narrative'."

1. In his evidence under cross-examination, Dr Keller's evidence was that the fact of the infidelity was not relevant, but rather Ms Cameron's thinking processes concerning the infidelity was one matter on which his diagnosis of Ms Cameron having a delusional disorder was based. Dr Keller gave further oral evidence on this point at the outset of his cross-examination, where he stated:

"Dr Keller: The question is not whether or not your husband was unfaithful; that is not for me to determine, but it was more about the way that you reached that conclusion. You presented some odd ideas about how you determined that that was the case, and that to me is the crux of the matter, not so much the fact of whether or not infidelity had occurred."

1. As if to underscore the fixed nature of her thinking, Ms Cameron asked Dr Keller for evidence concerning his opinion that she suffered from delusional disorder. His evidence, in response, was:

"Dr Keller: Historically, there was the evidence around the morbid jealousy, which was diagnosed with Othello syndrome, and which I have not seen any evidence to rescind. You told me, not only was your husband unfaithful, but you gave me the reasonings behind that, which I believe to be flawed inferences. For example, you said that there was lipstick on the collar, but that that was a deliberate sign put there by the woman with whom he was cheating, in order to give you a message. In my view, this constitutes sufficient evidence from a psychiatric perspective to make a diagnosis of morbid jealousy, which, in fact, seems to have happened."

1. In her submissions to the Tribunal, Ms Cameron said that the lipstick had been "very neatly drawn" on the collar of her former husband's shirt. We interpret that Ms Cameron intended, by making that statement, to provide a basis for why she considered the lipstick a sign from another woman, intended to be revealed to her. We consider that submission only confirms Dr Keller's findings regarding her impairment.
2. Ms Cameron informed Dr Keller about her current and prior physical health, including her breast cancer diagnosis in about 2015. Ms Cameron did not disclose to Dr Keller that she had been referred by the police for a mental health assessment in 2015. Ms Cameron also stated that she had suffered from postnatal depression after the birth of one of her children, for which she received treatment with antidepressant medication more than three decades ago.
3. In examining Ms Cameron's mental state, Dr Keller observed that, when she attended his rooms in May 2025 for assessment, Ms Cameron was neatly groomed but, carrying copious folders containing "lots of papers" - some typed, and some handwritten. Dr Keller noted that Ms Cameron's affect was "jocular" and that she frequently laughed and giggled, but that this jocular affect appeared to him to be more an affectation than an incongruity of affect. Dr Keller also noted that Ms Cameron was at times animated and expansive, expressing incredulity at others' comments, while at other times she paused and was hesitant, stating, sotto voce, "please don't write this down". That presentation was consistent with the way Ms Cameron conducted herself before the s 150 Hearing and at the hearing in the Tribunal.
4. Dr Keller assessed Ms Cameron's manner towards him as patronising; she referred to him at one point as "boy". That comment was made when Dr Keller had asked Ms Cameron whether her story might sound bizarre to some people, to which she replied, "You need to go and live out there, boy!" That exchange, which was not challenged by Ms Cameron, appears unprofessional, strange and troubling given the context in which it was said: a psychiatric assessment to determine whether she was impaired. It showed a lack of seriousness and an inappropriate tone for Ms Cameron to take in the setting of a psychiatric assessment. That outburst, however, was consistent with other thoughts expressed by Ms Cameron to Dr Keller, which he found revealed themes of grandiosity, including repeated name-dropping and overstatements of her own achievements. In his evidence given under cross-examination, Dr Keller, as part of his answer in response to Ms Cameron asking for examples of why he concluded that she was suffering from delusional disorder, said, on the question of grandiosity, that:

"Dr Keller: Your general manner was grandiose, and I made that point in my mental state examination, which is on page six of my report. The grandiosity covered all aspects of your developmental years from childhood through to early adult life and beyond. You overemphasised your connection to important people and overstated your accomplishments."

1. Name-dropping is a lamentable habit that many people, not suffering from a delusional disorder, exhibit. However, we do not take Dr Keller's conclusions in this regard in isolation - his clear evidence was that his opinion concerning Ms Cameron's condition was based on considering Ms Cameron's words, thought form, and the written evidence in its totality to arrive at the diagnosis and that included her grandiose manner.
2. Consistent with her manner and conduct at the s 150 Hearing and before the Tribunal, Dr Keller observed in his first report that:

"Ms Cameron's thought form was generally rambling and circumstantial. At its most severe, her thought form became tangential and derailed, her story was very difficult to follow."

1. In giving her account of the issues that had precipitated the assessment, Dr Keller noted that Ms Cameron displayed a fixation on a specific manager, she attributed undue significance to trivial events, and she appeared to entertain a range of popular conspiracy theories. Dr Keller also noted that Ms Cameron had a tendency to regard benign correspondence or interactions as posing a serious threat to her, to which she then responded in a way she regarded as consistent with her perception of the threat. Those kinds of responses are also noted by Dr Naidoo, as we note below. That kind of behaviour was apparent in the September 2024 email and in another incident of correspondence between the solicitor for the Council and Ms Cameron concerning the requirement that witnesses be available to give evidence at the Tribunal hearing. We have significant concerns that the behaviour exhibited by Ms Cameron, of reacting in ways that are out of all proportion to a misconceived threat that poses the created risk to patients, colleagues and the nursing profession.
2. Dr Keller considered that Ms Cameron exhibited deficits in both insight and judgment at the assessment. One less serious example was where she stated to Dr Keller that she did not need legal advice because when she did a TAFE business course, she topped the state in business law, and her over-use of legalese within her documents, which was a feature of her evidence and submissions at the hearing, was attributed by her to her TAFE course experience. Dr Keller noted that Ms Cameron struggled to see how others may find her story implausible or bizarre. In that regard, Dr Naidoo reported that Ms Cameron had admitted to him, at least, that others might find her story strange.
3. Dr Keller's opinion and recommendations arising from his assessment of Ms Cameron were as follows:

"In my opinion, Ms Cameron likely has a diagnosis of a psychotic illness, either delusional disorder or paranoid schizophrenia. These disorders are previously undiagnosed and untreated. I do note her reference to a psychiatrist diagnosing her with "Othello syndrome" (which can be considered equivalent to morbid jealousy, otherwise known as delusional disorder, jealous type). This likely represents an earlier form of her current condition. Nevertheless, there appears to have been a deterioration - both in her likelihood of experiencing problems in the workplace, as well as her mental state over recent years."

1. As we note below in paragraph [136] below, Dr Keller subsequently revised his differential diagnosis to delusional disorder or paranoid personality disorder rather than schizophrenia.
2. Dr Keller's recommendation arising from that opinion was that Ms Cameron be referred to her general practitioner or a psychiatrist for assessment and follow-up treatment. Dr Keller opined that Ms Cameron:

"... required assertive psychiatric management, including the use of medications if considered appropriate. This may result in a reduction of her impairment and allow future consideration of lifting her suspension."

1. Ms Cameron was given the opportunity to cross-examine Dr Keller about the findings set out in his first and supplementary reports. Ms Cameron's questions of Dr Keller in cross-examination were essentially directed to whether, if the underlying facts on which her beliefs were true, then a diagnosis of delusional disorder would be inappropriate. Dr Keller's evidence in cross-examination was to the effect that the way these issues were approached was more informative of a diagnosis than whether the suspicions or allegations were factually based. This was typified by the following exchanges:

"Ms Cameron: Oh, thank you. So, Dr Keller, if you're aware that none of the complaints that I put to New South Wales Health had been investigated, would that have put a different slant to your diagnosis, particularly if anything of what I said was true?

Dr Keller: No, because, as I've said, my assessment of you as being paranoid does not hinge on whether or not these events were based on fact, whether they were delusional or not delusional. The mere fact of all of the complaints that you've just outlined, that you've spent clearly a lot of time preparing and submitting, goes to the point of paranoia. It goes to a feature that's consistently seen in people with delusional disorder. If I may reference the DSM-5 criteria for delusional disorder. And I'm reading directly from the book, the DSM-5, under subtypes of delusional disorder. It talks about persecutory type. And it says, 'small slights may be exaggerated and become the focus of a delusional system. The affected individual may engage in repeated attempts to obtain satisfaction by legal or legislative action.' And that's what I'm relying on.

Ms Cameron: So, trying to get my back pay, is that delusional disorder?

Dr Keller: Not in and of itself, no. However, you've outlined a number of other complaints, submissions, many of them that I can't even remember because they've come so thick and fast. But clearly, that is consistent with, compatible with the statement I just read out from the DSM-5 in relation to persecutory delusional disorder.

Ms Cameron: I still haven't really been given any evidence, 'cause I've managed to give counter evidence of everything that I'd said. So I haven't seen any, you've not actually given any real evidence of actual paranoia. I can give evidence.

Dr Keller: I believe. Well, if I could respond to that question.

Ms Cameron: Yeah.

Dr Keller: I believe I've given copious amounts of information relating to paranoia. The last piece of information related to your persistent and repeated attempts to obtain satisfaction by legal or legislative action. Now that is a clear description that is contained within DSM-5 delusional disorder. I've also made reference to other aspects of paranoia in terms of the complaints you've made, the allegations you've made against people, whether it be about spiking your drink, whether it be about underpaying you, whether it be about people who have been dealing with you not being appropriate for their position because they've been sacked or because they themselves committed fraud. So, all of this in totality goes to my view that you exhibit paranoia."

"Ms Cameron: The question is the truth. Would you consider I'm very concerned that the psychiatrist's handbook that seems to almost diagnose somebody who has a strong desire for the truth as being paranoid. and the strong desire. Yes, so my question is, where does a desire for the truth lie? Where's that?

Dr Keller: I'm going to try and interpret that question as the comment that I made in relation to person seeking repeated attempts to obtain legal or legislative action, that this could be interpreted differently as a search for the truth. However, I'm not relying on that solely. I'm relying on that as part of an overall picture. Another direct quote from the DSM-5 description of delusional disorder, paranoid or persecutory type, the central themes involve the belief of being conspired against, cheated, spied on, followed, poisoned, maliciously maligned, harassed or obstructed in the pursuit of long-term goals. And I would argue, Ms Cameron, that you've demonstrated many of those particular aspects in your assessment with me, in the material that I was provided, and even today as we speak."

1. At the end of his cross-examination, Ms Cameron again raised the question of truth and its relationship with delusional disorder.

"Ms Cameron: ... So, basically, if somebody can give evidence of what you're saying is delusional, then are they delusional, is my question.

Dr Keller: They can be. As I mentioned before, the fact of your husband's fidelity or otherwise does not make the belief that their husband is unfaithful to be not a delusion. Again, I'm talking hypothetically now. People can have delusional beliefs where the facts of the matter stack up. However, the way that they came to that belief, the way they arrived at, the way they inferred from information they gathered, can mean that the belief itself is a delusion, particularly in delusional disorder, where the delusions are not bizarre; they're plausible, but they may still be delusions. That is the nature of delusional beliefs."

1. Dr Keller provided a further, or supplementary, report after he was asked by the Council to consider Dr Naidoo's report (which we discuss below) and answer some relevant questions which he set out in full in the course of responding. Dr Keller's supplementary report noted some points of agreement, including that Ms Cameron's psychopathology would make her vulnerable to external stressors, but ultimately concluded that nothing in Dr Naidoo's report changed his opinion that Ms Cameron is an impaired practitioner.
2. In considering Dr Naidoo's diagnostic comments (which we set out below), Dr Keller revised his opinion and considered that the main differential diagnosis was likely paranoid personality disorder rather than schizophrenia as he had originally opined. Dr Keller maintained his opinion that Ms Cameron was most likely suffering from delusional disorder. In that regard, Dr Keller noted that delusional disorder and paranoid personality disorder share many common characteristics and are generally regarded as being on a spectrum. He further noted that, if present, delusions are typically non-bizarre and well systematised.
3. Dr Keller referred to definitions for these disorders, which are part of a group of personality disorders called Cluster A, taken from the Diagnostic and Statistical Manual of Mental Disorders, Fifth Edition, Text Revision. Washington, DC, American Psychiatric Association, 2022 (DSM-5-TR), which describes paranoid personality disorder as:

"A pervasive distrust and suspiciousness of others such that their motives are interpreted as malevolent: beginning by early adulthood and present in a variety of contexts as indicated by four (or more) of the following ..."

1. Dr Keller then identifies four of the most relevant criteria from the DSM-5-TR, being that Ms Cameron:

"1. Suspects, without sufficient basis, that others are exploiting, harming or deceiving him or her.

2. Is reluctant to confide in others because of an unwarranted fear that the information will be used maliciously against her.

3. Reads hidden demeaning or threatening meanings into benign remarks or events.

4. Has recurrent suspicions, without justification, regarding the fidelity of a spouse."

1. Our review of the evidence, including Ms Cameron's evidence and submissions at the hearing, is consistent with the matters Dr Keller refers to above.
2. Dr Keller also agreed that the broad plan of management set out by Dr Naidoo appeared to be appropriate for the treatment of Ms Cameron's psychiatric issues. But Dr Keller also noted that her underlying condition is generally very resistant to any form of intervention, and he expressed the opinion that treatment, in and of itself, may not be sufficient to minimise the risks posed by Ms Cameron, in a workplace setting, to the health and safety of patients or the public interest. We accept Dr Keller's opinion in that regard and give it due weight in arriving at our decision.

Dr Naidoo's assessment and treatment recommendations

1. Ms Cameron was referred to Dr Naidoo by her general practitioner (now retired) for treatment and assessment. The referral letter was not in evidence, although Dr Cholakyan stated that he had a copy.
2. Given the extended nature of his contact with Ms Cameron, and the fact that he has prescribed medication for her to take, we are satisfied that Dr Naidoo's evidence should be regarded as evidence of Ms Cameron's treating specialist. That means Dr Naidoo has a different, and less objective role, than Dr Keller. We are also concerned that we have no information about the instructions given to Dr Naidoo in preparing his report. He does not, for example, expressly refer to s 5 of the National Law. Moreover, Dr Naidoo has obligations to Ms Cameron as a patient, whereas Dr Keller's role is a neutral expert. Dr Naidoo, in treating Ms Cameron, has, however, had the advantage of observing her over extended appointments, and his views and opinions carry some weight as a result.
3. Ms Cameron did not make Dr Naidoo available for cross-examination, and his absence has not assisted the Tribunal. Ms Cameron has submitted that she did not understand the process, but we reject that submission given that Ms Cameron was made aware in advance of the hearing that he was required to attend. We note that while Ms Cameron was self-represented, the Tribunal has previously urged her to seek legal advice and assistance in relation to these proceedings, including identifying some organisations that may provide her with pro bono advice and possible representation: Cameron v Nursing and Midwifery Council of NSW [2025] NSWCATOD 122 at [92]- [93].
4. What falls from the fact that Dr Naidoo is Ms Cameron's treating specialist and the fact that he was not made available for cross-examination is that we give less weight to Dr Naidoo's report than the evidence of Dr Keller. We decline, however, the Council's suggestion that no weight should be given to Dr Naidoo's opinions.
5. Dr Naidoo saw Ms Cameron before she was assessed by Dr Keller. Ms Cameron gave inconsistent evidence as to whether or not she told Dr Keller about seeing Dr Naidoo, but it is certain that she did not provide Dr Naidoo's details to Dr Keller. We conclude that it is unlikely she told Dr Keller that Dr Naidoo had seen her as a patient since Dr Keller makes no mention of it in his report. Given the scattered nature of her thinking and memory lapses that she exhibited at the hearing (including, for example, where she became confused about whether she saw a psychologist under the December 2024 mental health plan or under a mental health plan years earlier), and her particularity regarding what material should (and should not) have been before Dr Keller, we are not inclined to make a credit finding against Ms Cameron as proposed by the Council in submissions. Rather, we consider that her inconsistent evidence is indicative of Ms Cameron's possible impairment.
6. Dr Naidoo states that his report is predominantly based on information provided by Ms Cameron in interviews conducted between April and November 2025, as well as on documents provided by Ms Cameron. It is also apparent that Dr Naidoo was provided with access to materials relating to the s 150 Hearing (although he states he could not subsequently open that material, for example, to identify the date). Dr Naidoo had also read Dr Keller's first report and the referral letter from Canterbury Hospital in December 2023.
7. At the first consultation, which had been the result of a referral by her then-general practitioner, Ms Cameron complained of ongoing stress from dealing with the Council, as well as looking after her daughter, who lives with a disability. Ms Cameron told Dr Naidoo that, due to stress with the Council, and following some incidents, she had been unable to work or function normally. The relevant incidents included:

(1) Non-payment of money owed to her in wages and threats of legal action;

(2) Her belief that she had been the subject of cyber-bullying and suspected email tampering;

(3) Incidents of drink spiking and the suggestion by police that she was paranoid; and

(4) The inability to lock her door at the nurses' residence and the incident of another nurse threatening people with a knife - both relating to her position with the FWLHD at Balranald.

1. Ms Cameron set out her medical history as including breast cancer and post-natal depression. Ms Cameron disclosed to Dr Naidoo that she had seen a psychologist and psychiatrist when she was going through her divorce and that the psychiatrist had suggested she was suffering from Othello syndrome due to her beliefs about her husband's infidelity - a diagnosis that was retracted when Ms Cameron provided evidence to the psychiatrist of infidelity. From his report, it seems that Ms Cameron did not disclose to Dr Naidoo that she had seen or been assessed by Dr Turner in 2010 or 2015 or that police had referred her for assessment in 2015. It was also apparent from Dr Naidoo's account of Ms Cameron's history that he did not consider her email sent in September 2024, which we have quoted in full above, was unusual.
2. In his report, Dr Naidoo also provided a detailed family medical history, most notably that one of her sisters had been diagnosed with either anxiety and depression or bipolar affective disorder and that one of her daughters had been diagnosed with anxiety and depression, autism spectrum disorder (ASD) and attention deficit hyperactivity disorder (ADHD).
3. In relation to Ms Cameron's medical history, Dr Naidoo noted that:

(1) The referral to Canterbury Community Health dated 18 Dec 2023, referred to Ms Cameron as being casually dressed, having adequate self-care, pleasant, polite, good eye contact, affect reactive, good mood, affect congruent, not suicidal, evidence of anxiousness through her fast speech, no perceptual disturbance or paranoia; and that no psychiatric diagnosis was suggested or intimated. Dr Naidoo considers that this assessment was most relevant as it was temporally closest to when Ms Cameron might have been considered to be psychiatrically ill. We note three matters with regard to Dr Naidoo's findings and opinion concerning the 2023 mental health assessment.

(a) First, Ms Cameron did not disclose to Dr Naidoo that a similar event occurred in 2015 when police also referred her for psychiatric assessment so the Tribunal cannot have the benefit of his considered opinion in that regard.

(b) Second, the report to the Respondent was not made in December 2023 but was instead triggered after Ms Cameron sent the email in September 2024, which we have extracted above in full and about which Dr Naidoo does not express any opinion.

(c) Third, Dr Naidoo does not address Ms Cameron's strange belief that one of the nurses at Canterbury Community Health was not a mental health care nurse but was instead another diabetes educator who was impersonating a mental health nurse.

(2) In December 2024, Dr Cholakyan had declared her fit for work. Once again, we note that Dr Naidoo does not reference the September 2024 email in relation to Dr Cholakyan's declaration.

(3) After assessing Ms Cameron on 22 May 2025, Dr Keller had considered a diagnosis of undiagnosed and untreated delusional disorder or, as a differential diagnosis, paranoid schizophrenia with active symptoms of psychotic illness.

1. On examination, Dr Naidoo reported that he found Ms Cameron to be cooperative, pleasant, socially appropriate, stated that she was not depressed, never suicidal, up and down mood due to Nursing Council stress, quite anxious, agitated, frustrated, annoyed, her speech was voluble, expansive and showed exasperation, however showed no sign of thought disorder or flight of ideas, no evidence of hallucinations, passivity phenomena delusional mood or psychosis, no complaints of memory, she was grossly oriented, concentrated and attention was variable and often remained unfocused on the task, however retained insight. Dr Naidoo noted her presentation seemed quite different from that which Dr Keller had described and suggested that this may be due to Ms Cameron experiencing anxiety, which is exhibited by obsessionality, and that she likely perceived the interview with Dr Keller as being stressful or confrontational as compared with the interviews he conducted.
2. Dr Naidoo concluded that Ms Cameron was not displaying any symptoms suggestive of an acute psychotic disorder, nor acute depressive illness, nor hypomania. He found, however, that Ms Cameron displayed inconsistent symptoms that suggested stress-induced or reactive anxiety with secondary feelings of despondency or dysthymia. Dr Naidoo did not find anything to suggest a chronic or relapsing psychiatric dysfunction and stated that if Ms Cameron in fact suffered from such a serious condition, it would be "inconceivable" that she could have withstood the stress of ongoing nursing commitments without decompensating or succumbing to regular illness. Rather, Dr Naidoo opined, Ms Cameron's history suggested that there had been two specific stressor-related events causing discrete episodes of psychiatric disorder: her postnatal depression and the problems following her marriage breakdown. But that opinion fails to take into account the circumstances of her dismissal from Janssen and the issues she reported experiencing while working at Balranald - each of those incidents occurred in the work environment. Unfortunately, since Ms Cameron did not make Dr Naidoo available for cross-examination, the Tribunal cannot know if his opinion would differ if those matters were further considered.
3. As the Respondent points out in submissions, Dr Naidoo did not address in his report how Ms Cameron's behaviours and communications style, as exemplified, for example, by her September 2024 email (extracted above), might be likely to impact her nursing practice. He does not opine on whether, given the evidence that she has misinterpreted benign events and interactions as being threatening, it is likely she might misinterpret the behaviour or actions of colleagues and patients, or whether she is capable of receiving constructive feedback or accepting supervision. The Tribunal would have been greatly assisted to know Dr Naidoo's views on these issues. As it stands, the Tribunal can only rely on Ms Cameron's documented history and Dr Keller's opinion in this regard.
4. Dr Naidoo then considered six differential diagnoses, finding that:

(1) There was little evidence to suggest, and no prior complaints of, a possible chronic psychotic illness.

(2) As Ms Cameron accepted that she might be wrong about the drink spiking, she demonstrated that she did not hold such views with "delusional intensity" and thus, she was unlikely to be suffering from a delusional disorder. Rather, her over-valued ideas were understandable in Ms Cameron's socio-cultural context and were not necessarily indicative of a psychiatric disorder.

(3) Ms Cameron did not exhibit any symptoms during Dr Naidoo's examination, which could lead to the conclusion that Ms Cameron was suffering from a depressive episode with persecutory symptomology.

(4) Any hypomanic episode now resolved was not apparent and not considered by Dr Keller. Dr Naidoo found Ms Cameron had no disturbance of sleep or physical overactivity or flight of ideas.

(5) There was no evidence to support or require further investigation of whether Ms Cameron was suffering from an organic disorder causing psychiatric symptomatology.

(6) The more likely explanation, according to Dr Naidoo, was that Ms Cameron was displaying a characterological anxiety disorder and that she experienced symptoms which included episodes of acute anxiety on a backdrop of a generalised anxiety disorder. Dr Naidoo considered there was a possible genetic vulnerability, having regard to Ms Cameron's history of postnatal depression and her sister's mental health condition.

1. Dr Naidoo concluded that Ms Cameron's long-standing personality traits had made her vulnerable to stressors and that, with age and decreased work commitments, she had become increasingly anxious and obsessional. Dr Naidoo opined that:

"... it is my opinion that the patient clinically shows features of an anxiety disorder together with obsessionality, and that both are the result of underlying personality traits conflicting with the life stressors that impinge upon her. ... I believe that she also appears to have some neurodiverse traits and symptoms related to Autism Spectrum Disorder."

1. We note in passing Dr Keller's views, expressed in his supplementary report, on obsessional personality traits and whether Ms Cameron may have an autism spectrum disorder. Having observed Ms Cameron and having regard to the totality of the evidence, we prefer the opinion of Dr Keller on these points, where he had opined that:

"I disagree with Dr Naidoo that obsessional personality traits predominate and are a reasonable alternative to the possibility that she has overvalued ideas (or even delusions). Although both overvalued ideas and obsessions can dominate a person's mental activity, it is important to differentiate between the two. Unlike obsessional thinking, a patient with overvalued ideas does not try to fight the idea but instead relishes, amplifies and defends it, resulting in the idea becoming more resistant to challenge. In my opinion, the predominant characteristic of Ms Cameron's thinking is overvalued ideas, and not obsessional thinking.

Finally, I disagree with Dr Naidoo that Ms Cameron has an autism spectrum disorder. The evidence presented for the diagnosis of this disorder appears to hinge on two factors - a family history, given that her daughter has been diagnosed with same; and difficulties with social communication in her personal relationships. In my opinion, the latter is better explained by her paranoid thinking and rigidity, which are not sufficient on their own to make a diagnosis of autism."

1. Dr Naidoo then reported that he considered that the best management of Ms Cameron's symptomology was a combination of medications for anxiety coupled with psychotherapy, and that he had discussed with Ms Cameron the benefits of controlling her anxiety. As a result, Dr Naidoo had prescribed Ms Cameron the medication Escitalopram, which he described as an anti-depressant, but which the Tribunal understands is also prescribed as a mood stabiliser. Considering Ms Cameron's concerns over side effects, Dr Naidoo prescribed a low starting dose of that medication. Dr Naidoo suggested that this prescribing course was consistent with Dr Keller's opinion about psychiatric management and use of medications if considered appropriate.
2. In her evidence given under cross-examination at the hearing, Ms Cameron stated that Dr Naidoo had prescribed the medication referred to in his report at their last appointment, that she had taken two doses of it but that it made her feel "very dizzy" and that, as she was not presently feeling anxious, she had not taken any further doses. Somewhat confusingly, in her closing submissions, Ms Cameron stated:

"Ms Cameron: ... Certainly, I've been anxious at the moment, and I did start on his medication in good faith. I found it made me feel slightly drunk, so I thought, well, so I pulled back on that. But I still have it. Yeah, if I was feeling excessively anxious or whatever, I would be happy to do that. ..."

1. Counsel for the Respondent submitted in oral closing submissions that the Tribunal would have some concern that Ms Cameron does not appear to be following a recommendation of her treating practitioner, and that this failure reflects a lack of insight into her condition and the necessity that she have treatment, including medication. We agree with that submission.
2. Moreover, Ms Cameron's decision not to take the medication speaks to her lack of judgment. Ms Cameron gave no evidence about raising her concerns with the medication's side effects with either Dr Naidoo or Dr Cholakyan in order to see whether there was, for example other medication that was more suitable for her to take or a different dosing regimen; instead, she simply determined that she would decide when, or if, she would take medication in a manner that is entirely contrary to the views of her treating specialist. We did not detect any apparent barrier to Ms Cameron exploring the issue of medication adjustment with either Dr Naidoo or Dr Chalayan. To the contrary, Dr Naidoo appears to have taken great pains to establish a therapeutic alliance with Ms Cameron, including considering her concerns about medication side effects. While our impression of Dr Cholakyan was that he was highly supportive of Ms Cameron and willing to assist her as far as possible.
3. Ms Cameron's approach to taking the prescribed medication also suggests that she lacks the relevant clinical knowledge expected of a nurse of her qualifications and experience. It is concerning that Ms Cameron appeared unaware that the medication prescribed for her by Dr Naidoo is not a pro re nata or "PRN" medication, which means a medication that can be taken as needed. Instead, the kind of medication prescribed by Dr Naidoo is one that needs to be taken for longer periods of time on a schedule as directed by the prescriber to treat anxiety or other conditions.

1. In considering whether a condition should be imposed, the Tribunal is required to consider whether the condition is necessary to protect the health and safety of any person or persons. Again, we note that it is not required that an actual risk be identified in that regard; rather, it is sufficient to identify a potential risk of harm and then consider what conditions might be imposed to ameliorate that risk.
2. We are satisfied, based on the evidence and findings set out above, that Ms Cameron is currently suffering from symptoms that are consistent with a delusional disorder. She has been prescribed medication for anxiety by her treating psychiatrist, but has decided not to take it, saying that she does not presently feel anxious and that the medication, which she tried for two doses only, made her feel dizzy or a little drunk.
3. The expert evidence and her presentation at the hearing suggest that her illness is both symptomatic and untreated, and she shows a concerning lack of insight about it and a lack of judgment with respect to treatment and modification of treatment.
4. Her symptoms, lack of insight, and lack of judgment are all matters that are likely to undermine the public's confidence in the nursing profession and put at risk the public interest. Accordingly, we consider it appropriate to make her registration subject to the condition that she does not practice as a registered nurse. We do not consider that any other, less restrictive conditions could be imposed in this case.
5. We encourage Ms Cameron to seek appropriate treatment from her treating psychiatrist, and that her treating psychiatrist be given full information concerning the extent of her persecutory and other delusional behaviours in order to provide her with appropriate care.
6. As we noted in paragraph [13] above. The Nursing standards are relevant to our consideration of whether Ms Cameron poses a risk to the health and safety of any person or persons, or to the public interest.
7. Standard for Practice 2.2 requires a registered nurse to communicate effectively and be respectful of a person's dignity, culture, values, beliefs, and rights. In these proceedings, there was evidence of breach of this standard through a demonstrated lack of respect. That lack of respect was evident as early as April 2024, when NSW Health sent Ms Cameron a letter requiring her to cease and desist from harassing its staff. That incident is outlined in paragraph [57] above. A letter such as that is not typical and would only have been sent in response to extreme and unacceptable conduct by Ms Cameron.
8. Further examples of a lack of respect for others were apparent in the course of the Tribunal hearing, where Ms Cameron:

(1) Referred to people living with schizophrenia as 'schizophrenics', which would have been somewhat acceptable had the reference not then been accompanied by statements such as "schizophrenics can't hold down jobs and generally display antisocial behaviour." That statement is stigmatising, ill-informed, and disrespectful.

(2) Made comments about race, to the effect that persons with a similar ethno-racial background tend to look the same. This occurred when she was cross-examined about her belief that she had been assessed at Canterbury Community Health by a diabetes educator and not a mental health nurse. In that regard, her evidence was:

"Ms Cameron: ... I mean, there's lots of Filipino nurses who look the same, have the same age and what have you. We can all look a bit similar."

1. Standard for Practice 2.2 requires a nurse to communicate effectively. In that regard, the Tribunal has received a large volume of repetitive information from Ms Cameron. That material indicated a difficulty Ms Cameron has in communicating effectively. Her written evidence was couched in bizarre terms and referenced odd things. When directly asked what some of the things she had written meant, she was unable to explain.
2. Her evidence was also consistently poorly prepared; for example, Ms Cameron supplied a death notice of a person who lived in Balranald. She did not make submissions about who this person was or what the death had to do with her application to have the s 150 decision overturned. Through some effort, we could infer that Ms Cameron had tendered this material to support her allegation that the person had died as a result of drink spiking and that she had included the death notice from some unknown source to prove that the death occurred - all of which was intended, via a circuitous and unexplained route, to support her argument that a drink she had ordered from the same hotel had been spiked, and therefore she was not delusional in saying that it had been and presenting herself to Campsie police station when she returned to Sydney to report the matter.
3. Consistent with the way in which her evidence was prepared, Ms Cameron's written submissions were also hard to follow because her ideas were not connected in a meaningful or logical way. Bizarre terms and jargon were also a feature of her submissions, as was her evidence, which had to be read and considered. When asked, for example, why she had typed "British subject and private person" at the end of one of her documents, she said she did not know why, as she was not a solicitor.
4. There were other strange references in her materials, for example, to the dissolution of "Washington", but when queried about these matters, Ms Cameron suggested that the material had been inserted into her submissions by another person. If that is the case, then it shows a disturbing lack of judgement to have allowed the inclusion of such material and it stands as another example of conduct consistent with Dr Keller's opinion that Ms Cameron is suffering from impairment.
5. Ms Cameron's oral evidence also showed significant disordered thoughts. Many of the extracts above in our findings show the rambling and difficult-to-follow nature of her oral evidence. A further example was this exchange:

"Counsel: Before you start speaking, I'll just ask the question. You're looking at that paragraph that refers to international group. Can you tell the tribunal what is the international group that you have referred to the complaint to?

Ms Cameron: Can I just have a little read of this? Okay, so now Aunty Marlene is here as well. There's quite an issue and my agency confirmed this. Quite a number of the contractors are not getting paid the lawful contract rate by the health departments throughout Australia. When I was at Balranald Health Service, we had at least five after I left, I think there were four nurses who had to be backpaid and other staff. One of my colleagues who was the head nurse for the union had needed to be backpaid dated back to 2021, and she only got it at the beginning of this year. So we've got a systemic issue with corruption, whether we like it or not, or whether we see it or not. Now, when I worked at Concord, I saw a very shocking thing there that alerted me to possible corruption, where the people who put our IT information in, we became the first hospital in Australia at Concord. That was a Veterans Affairs repat at the time they had just become State. The IT people knew I was working two days a week, but my neighbour happened to work for digital.

Counsel: I'll just stop you there. I do want to finish this cross-examination today. Can you tell the tribunal, is there a name for this? international group.

Ms Cameron: Marlene, do you want to?

Counsel: No, sorry, you can't ask

Ms Cameron: Okay. It is actually the US military, part of the US military. It's the same as Trump now has asked us to they've asked people to expose issues with corruption. For whatever reason, the US is happy to look at our issues if they think that we're not getting justice. And there were a significant number of nurses at that location where I worked who were subject to wage theft. There was some anomalies with the bonuses where they were delivered, like, six months late. And noting our manager was I don't know if I'm allowed to say what her other role was. Do you know what her?"

1. What emerged from her evidence and submissions was a concerning lack of clarity in her verbal and written communication. There was little evidence before us of how Ms Cameron records her work in a clinical setting, but, having regard to the materials she tendered and her extensive correspondence, we have to consider the possibility that her clinical records echo this pattern.
2. Many clinical incidents occur because of poor communication, and a demonstrated inability to communicate clearly does put patients at potential risk of harm. Ms Cameron, as a diabetes educator, would be expected to have a very high level of verbal and written communication skills and would need to demonstrate agility in processing and exchanging information with patients and other health professionals. Based on the evidence before us, we do not presently believe Ms Cameron can communicate at the level required by the Standards for Practice, due to her impairment.
3. Standard for Practice 3 is "maintains the capability for practice." Subsidiary to that is Standard for Practice 3.1: "The RN considers and responds in a timely manner to the health and well-being of self and others in relation to the capacity for practice."
4. We have already set out our concerns arising from Ms Cameron's disclosure that she has elected not to take the medication prescribed by Dr Naidoo. In that regard, it is apparent to the Tribunal that Ms Cameron is not attending to her own well-being, which is essential when providing care to others.
5. If, as we have noted elsewhere in these reasons, Ms Cameron seeks to apply for the condition to be removed from her registration, we consider it vital that she demonstrate that she can take care of herself, including the impairment that has been manifest in the evidence before the Tribunal in these proceedings. That would include taking medication prescribed and undertaking the necessary other therapies as directed by her psychiatrist.

1. The Council has submitted that, if Ms Cameron's appeal is dismissed, it seeks its costs in the proceedings.
2. The award of costs in matters such as this is discretionary: National Law, Sch 5, cl 13(1).
3. Costs are intended to be compensatory, and, as a general rule, costs should be awarded to the successful party in the absence of any disentitling conduct on its part: Health Care Complaints Commission v Philipiah [2013] NSWCA 342 at [42]- [46]; Health Care Complaints Commission v CSM [2016] NSWCATOD 125 at [98].
4. Here, Ms Cameron has been entirely unsuccessful in demonstrating that the condition on her registration preventing her from practising should be removed. There has been no disentitling conduct on the part of the Council that would cause us to exercise the discretion other than to order that Ms Cameron pay the Council's costs of these proceedings.
5. The quantum of those costs will be a matter to be negotiated between the parties (that is, "as agreed") or as determined by a cost assessment (that is, "as assessed"). The costs are ordered to be paid on the ordinary basis as we do not consider that, for example, it would be appropriate to burden Ms Cameron with the Council's costs on a higher basis.

1. The condition on Ms Cameron's registration effectively prevents her from practising as a registered nurse. We consider, having regard to the totality of the evidence before us and our consideration set out above, that this condition is necessary for the protection of the health and safety of persons, and that it is otherwise in the public interest.
2. Having regard to the medical evidence available to the Tribunal, it may be that the conditions imposed on Ms Cameron's registration can be reconsidered if her condition can be successfully managed through, as Dr Keller has described it, assertive treatment.
3. Presently, however, Ms Cameron's condition is untreated and unmanaged, and we consider that allowing Ms Cameron to practise as a registered nurse creates an unacceptable risk to the health and safety of the public or otherwise involves an unacceptable risk to the public interest.
4. Accordingly, we make the following orders:

(1) The decision of the Nursing and Midwifery Council of New South Wales to impose the condition on the registration of Therese Cameron that she not practice as a registered nurse is confirmed.

(2) Pursuant to the Health Practitioner Regulation National Law (NSW), Sch 5D, cl 13, Therese Cameron is to pay the costs of the Nursing and Midwifery Council of NSW of and incidental to these proceedings as agreed or assessed under the Legal Profession Uniform Law Application Act 2014 (NSW), on the ordinary basis.

(3) The application for external appeal is otherwise dismissed.

27 March 2026 - Order (2) corrected - "Health Care Complaints Commission" replaced with "Nursing and Midwifery Council of NSW".

I hereby certify that this is a true and accurate record of the reasons for decision of the Civil and Administrative Tribunal of New South Wales.

27 March 2026 - 27 March 2026 - Order (2) corrected - "Health Care Complaints Commission" replaced with "Nursing and Midwifery Council of NSW".