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[1998] VSC 97
Supreme Court of Victoria
1998-10-02
HEDIGAN, J.
Original judgment source is linked above.
ACCIDENT COMPENSATION ACT 1985 as amended - Section 45(1) - Appeal from Magistrate's order that insurer make weekly payments - Whether Magistrate in error in deciding which medical opinion as to contribution of employment to incapacity was correct. MEDICAL QUESTION - Section 45(1) of the Act - Whether Court obliged to refer to Medical Panel - Whether in the circumstances error to refuse to refer question because Magistrate had decided what answer was.
"5. On or about the 10th of June 1996 the plaintiff sustained injury in the course of his employment with the employer. Particulars of injury: low back injury, L5-S1 disc prolapse, lumbar spine injury, referred left and right leg pain and numbness, reactive depression, anxiety."
The plaintiff pleaded having made a claim for weekly payments of compensation in respect of the work injury and that the defendant accepted the claim and made WorkCover payments. He went on to plead that on or about 27th May 1997, he made a further claim for weekly payments of compensation pursuant to the Act and that on 23 June 1997 the defendant determined to reject the second claim and notified the plaintiff of that on that date, re-affirming its decision on 28 July 1997. The plaintiff alleged his incapacity for work and made routine claims for weekly payments of compensation under s.93 and associated expenses and costs. The defendant's defence was basically routine admissions, non-admissions and denials. The claim form lodged by the respondent on 23 May 1997 (that is, after the home accident) claimed for the worker's time off work and expenses. It described the injury/condition as "prolapse disc" and "spinal stenosis", affecting the lower back. With respect to what happened to cause the injury/condition in respect of which the claim being made it was stated "Re lapse (sic) of previously reported injury". The substantial affidavit of the solicitor for the appellant sets out details of the evidence in the proceeding which I consider in conjunction with the findings of fact of the Magistrate, and his expression of reasons. Both that affidavit and an affidavit on behalf of the respondent's solicitor raised some matters that seem to lie outside the factual matrix that had to be considered by the Magistrate. It would seem to me nothing much turns on this as both parties to this appeal sensibly approached the matter by going directly to the issues that did emerge from the affidavits and the reasons.
"45 Medical questions (1) Where the County Court exercises jurisdiction under this Part, the County Court - (a) may refer a medical question; or (b) if a party to the proceedings requests that a medical question or medical questions be so referred, must refer that medical question or those medical questions - to a Medical Panel for an opinion under this Division."
This provision applies in a case where it is the Magistrates' Court exercising jurisdiction.
"Whether the worker's employment was in fact, or could possibly have been, a significant contributing factor to an injury or alleged injury, or to a similar injury."
It appears that from the outset counsel for the respondent contended there was no relevant medical question arising in the proceedings and opposed the insurer's request to refer that question to a medical panel. The Magistrate decided to reserve his opinion about that until he had heard oral evidence.
(a) whether the Magistrate erred in failing to consider whether any medical questions within the meaning of s.5 of the Act arose in the proceeding;
(b) whether he erred in failing and/or refusing to refer any medical questions to a medical panel in accordance with s.45 of the Act;
(c) whether the learned Magistrate erred in failing to make findings of fact before deciding if the respondent was entitled to compensation.
(c) does not appear to have been addressed by either counsel and I will not refer to it again.
"He has evidence of congenital spinal stenosis which I consider to be the underlying cause of his continuing symptoms. He sustained a further acute exacerbation of pain at home on the 6 March, 1997 and I do not consider that this would be part of an ongoing condition. This would need to be considered as a new incident."
**"**Throughout the presentation of the plaintiff's case these two propositions of Mr. Guest, namely that a congenital spinal stenosis was the underlying cause of the plaintiff's continuing symptoms and that the incident at home on 16 March, 1997 would need to be considered a new incident, were put vigorously to each medical practitioner called on behalf of the plaintiff. Each of these witnesses, Dr. Gault, Mr. Maling and Mr. Schofield each vigorously denied the propositions and positively averred that as the plaintiff had never had nay previous back trouble canal stenosis nothing to do with his condition and that his present condition was a result of the incident at work which had occurred on 10 June, 1996 when the plaintiff was lifting a trailer up to a tow bar. I rejected the twin propositions contained in Mr. Guest's report. I did so because of his apparent wilful and persistent refusal to come to Court to justify himself, because of the plaintiff's evidence which I have accepted, because of the weight of the medical evidence given by the practitioners called on behalf of the plaintiff and because they do not accord with common experience and common sense. In rejection of Mr. Guest's propositions, in the light of the thrust of the totality of all of the acceptable medical evidence, in the acceptance of the plaintiff's own evidence of continuing pain and disability from the first incidence without resolution and in the defendant's acceptance of liability for the first incident, the proposed medical question must be irrelevant and I so found. This irrelevant question was not, then, referred to the Medical Panels."
"Whether the worker's employment was a significant contributing factor to the injury for which he claimed compensation by way of claim form dated 23rd May 1997."
Mr. Purcell's affidavit states that on 19 March the Magistrate indicated that if he was entitled to find as a question of fact that Mr. Guest's opinion was wrong then there was no question or issue to be referred to a panel saying "If I find the worker was incapacitated from March 1997 because of the June 1996 injury then there is no question to go to the panel". It appears the insurer argued that the court could make findings of fact but not about issues sought to be referred to the panel. He also states that the Magistrate adjourned the case to think about it, intimating that in the event of deciding to send a medical question to a panel he was not satisfied the present question was the most appropriate one because it must encompass questions in relation to the whole history of the respondent's claim as presented by the respondent. On 30 March, the respondent failed in an application to have Mr. Guest called as a witness.
"Mr. Greeves still has a moderate incapacity. However I do not consider that the work related injury is now contributing to this, but it is linked with the spinal canal stenosis from which he is suffering. ... I do not consider there is any work related permanent impairment but Mr. Greeves does have a permanent impairment and he will need to consider a change of job and life-style."
(1) Where the County Court exercises jurisdiction under this Part -
(a) the court may refer a medical question to a medical panel for an opinion; and
(b) if a party to the proceedings are requests, the court must refer a medical question to a medical panel for an opinion; and
(c) the opinion of the panel on that question shall, subject to this section, be adopted by the court as the answer to that question."
" It will be recalled that the employer requested the reference. In these circumstances, s. 45(1)(b) provides that the Magistrate must make a reference to the medical panel. This is to be contrasted with its predecessor, s. 60(1), which was introduced in the Act by No. 64 of 1989 and repealed by Act No. 67 of 1992, under which the court was given a discretion to refer a medical question to a medical panel. Nevertheless, as Judge Williams points out in Green v. VWA (unreported, 16 November 1995), where a request for reference has been made, the stage of the trial at which the reference is made and the terms of the questions themselves remain for the court to determine. .... Judge Williams in Green v. VWA ... mentions also the possibility that the court might even refuse a request where the reference requested would be an abuse of process. Such an abuse might arise where the issues before the court raise no medical question. Such qualifications as may exist upon the obligation of the court to accede to a request for referral, all stem from the power and the duty of the court to control its own procedures so as to ensure that justice is done to the parties. It would be very surprising if Parliament, without the clearest statement of this intention, intended to remove from the court the power to use and mould the procedures available to it to achieve this objective and to leave these matters to the requesting party. No such statement appears in s. 45. Paragraph (a) of s. 45(1) confers on the court a general power to refer. Paragraph (b) is in these terms:
'(b) If a party to the proceedings so requests, the court must refer a medical question to a medical panel for an opinion;'
As a matter of construction there are two steps involved here. First, is the request of a party for the court to exercise its jurisdiction under s. 45(1); the second is the reference by the court of a medical question to a medical panel. Subject possibly to the case of abuse of process, the obligation of the court is to refer a medical question. It is not to refer the very medical question which the party requests. Neither is it to refer to the medical panel every question before the court which falls within the statutory definition It is consistent with this provision that it remains with the court to determine not only the appropriate time for the reference, but also what medical question should be referred and its terms."
"7. A number of changes will be made to improve the efficiency of the dispute resolution process. Opinions of the medical panels will be made final and conclusive irrespective by whom and when the medical question was referred and must be adopted and applied by the courts and all other decision makers in the scheme is the answer to the medical question."
The Government considers that doctors, not lawyers, are the best qualified people to offer medical opinions. Currently the opinion of a medical panel on a medical question is binding only when a court has referred a medical question to the panel. This gives rise to 'duelling experts', which becomes an obstacle to the resolution of disputes, and drives up costs unnecessarily.
Therefore, in line with the practice in other jurisdictions, the Act will require that the opinion of a medical panel on a medical question be final and conclusive irrespective of by whom and when the medical question was referred and must be adopted by the courts and all other decision-makers in the scheme as the answer to that question."
HIH Winterthur Workers' Compensation (Vic) Ltd
Greeves [1998] VSC 97