[3] The plaintiff claims damages for personal injury sustained in his employment as a paramedic.
[4] In 2004 he was stationed at Mount Isa and from time to time would relieve at the Doomadgee Ambulance Station. He alleges there were three incidents which occurred over a seven week period in the course of his employment at Doomadgee.
[5] The first incident, on 30 September 2004, involved the plaintiff attending upon a young naked male who had been badly mauled by a pack of dogs. The boy's testicles and part of his penis had been chewed off and his entrails ripped from his abdominal cavity.
[6] The second incident, on 16 October 2004, involved the plaintiff attending to a three year old child victim of sexual assault, the details of which were described to him by the child's father.
[7] The third incident, on 13 November 2004, involved the plaintiff's attendance upon a six year old victim of sexual assault whose genitalia were oozing blood.
[8] In his claim filed 19 August 2008, the plaintiff pleaded that in consequence of his involvement in the three incidents he suffered psychiatric injury, namely chronic post-traumatic stress disorder. He pleaded he was exposed to the risk of such injury as a result of his involvement in the incidents and the defendant knew or ought to have known of the risk. He pleaded, inter alia, any system the defendant had in place to obviate or ameliorate the risk was inadequate and not a sufficient response to the risk.[2] It was further pleaded the defendant failed to provide and maintain a safe system of work for the plaintiff and failed to provide appropriate assistance and support "following upon the plaintiff's involvement in the incidents over an interval of less than seven weeks".[3]
[9] In committing these and other acts and omissions, the defendant was alleged at paragraph 28 of the amended statement of claim to have been negligent and in breach of its duty of care to the plaintiff and further or alternatively at paragraph 28 to have been in breach of its statutory duty of care owed to the plaintiff and or its contract of employment with the plaintiff. But for those breaches, it was pleaded, the plaintiff would not have suffered his illness or would have completely recovered from it or its extent and consequences would have been very much ameliorated.
[10] The defence included a pleading that the defendant had in place a system of counselling and peer support, called Priority One, under which employees experiencing traumatic or stressful events would receive support, counselling, debriefing or other psychological intervention. Components of the Priority One Peer Support Programme include a Critical Incident Stress Debriefing ("CISD") and "Notification/Activation of Priority One/Peer Support" under Standing Operating Procedure 47 ("SOP 47").
[11] As to causation, the defence pleaded, inter alia, that the plaintiff suffered other concerns which may have materially contributed to his illness, including: