COX CJ The facts and circumstances of this appeal are set out in the reasons for judgment prepared by the other members of the Court and I need not repeat them. At the conclusion of the submissions of counsel for the appellant, the Court dismissed the appeal and said it would deliver its reasons at a later time. I agree in substance with the reasons published by the other members of the Court and confine myself to the following brief observations.

2. Payments of weekly compensation to an injured worker are due, as the Workers Compensation Act 1988 ("the Act"), s69 provides "where total or partial incapacity for work results from an injury suffered by a worker" and where the existence of such a total or partial incapacity is supported by an appropriate medical certificate. Once commenced, a weekly payment may not be terminated or reduced by an employer, save in the circumstances set out in s86. Among those circumstances are those set out in s86(1)(c), namely, where a medical practitioner who has examined the worker has certified that, in his opinion, the worker has wholly recovered or substantially recovered from the effects of the injury in respect of which the payment is being made or that the worker's incapacity is no longer due wholly or substantially to that injury. Subsection (2) requires that such a certificate specify the grounds upon which the opinion expressed is given.

3. It is to be noted that the statute does not in terms require the certificate to state what the effects of the injury are. In a sense it would be otiose to require this to be done for the only relevant effects of the injury are that the worker is thereby incapacitated, totally or partially, for work. Physiological effects may include non-incapacitating effects such as scarring or other cosmetic consequences, or they may include sequelae affecting the worker in such a way that his capacity to work is no longer impaired. Unless incapacity for work results and substantially continues, no weekly compensation is payable. Little purpose would be served by a certificate which addresses non-incapacitating effects or which is merely descriptive of incapacitating effects. Its purpose is to authenticate the medical practitioner's opinion that either the worker has wholly or substantially recovered from the incapacity (whole or partial) occasioned by the injury in respect of which the payment is being made to the worker or that the incapacity thus occasioned is no longer due wholly or substantially to that injury. If that state of affairs is accepted by the worker, once he has been given notice of the employer's intention to terminate or reduce weekly payments and has been given a copy of the certificate, the employer is relieved of the obligation to continue such payments for there will be no longer any basis for the payments to be made. If the worker does not accept it, he may refer the matter to the Commissioner.

4. In many cases it may be necessary in stating adequately in the certificate the grounds for the medical practitioner's opinion, to address the worker's symptomatology and to describe the past or subsisting effects of the injury. Nevertheless, I agree with the learned primary judge that a certificate which does not identify them, but which otherwise complies with the subsection, should not be regarded for that reason alone and in every case as necessarily invalid for the purposes of s86(1)(c). The Commissioner was in error in holding that the certificate in this case did not comply with the requirements of s86 and the orders of the learned primary judge remedying that error should not be disturbed.

UNDERWOOD J The issue on this appeal is whether Crawford J erred in setting aside an order made on 24 January 1996 by Commissioner Hemming sitting as the Workers Rehabilitation and Compensation Tribunal. The order provided: "After hearing the parties herein on 11th December 1995 I order that payments of compensation resume as and from the date of the determination." It did not provide as was recited in the notice of appeal determined by Crawford J: "... the certificate does not comply with the requirements of section 86 of the Workers Rehabilitation and Compensation Act 1988 and it is hereby ordered that payments of compensation resume as and from the date of termination." Had it so provided, the words "the certificate does not comply with the requirements of section 86 of (the Act)" would have been otiose for the Workers Rehabilitation and Compensation Act 1988, s61, relevantly requires the Tribunal to make an order that: (i) gives effect to a determination; and (ii) directs that what is required to be done by the order shall be done within the time specified in the order.

2. The matter the Tribunal had to determine was the appellant's entitlement to weekly compensation, payments of which had been terminated in purported reliance on s86(1)(c). The basis for the Tribunal's order appears from the reasons of the learned Commissioner. He found as a fact "that there is nothing in the certificate which identifies what the effects of (the) injury were" and ruled as a matter of law, that a certificate which fails to identify the effects of an injury is not a certificate within the meaning of s86(1)(c).

3. Attention is drawn to all this, not to be pedantic, but to make the point that as appeals from the Tribunal are limited by the Act, s63(1) to points of law, the issues properly raised by the appellant before Crawford J were not whether the certificate in this case complied with s86(1)(c), but whether: (i) upon a proper construction of s86(1)(c), identification of the effects of the relevant injury (inter alia) is a condition of validity of the medical certificate; and (ii) the Tribunal's finding that "there was nothing in the certificate which identifies what the effects of (the) injury were" was not one reasonably open to the learned Commissioner?

4. As to the second issue, the finding of fact was clearly one which the learned Commissioner could reasonably have made. Although it is not necessary to go further than that, I express agreement with Crawford J that the finding of fact was "plainly right." That leaves the first issue. The Certificate

5. The certificate provided: "I, Dr J L Roth, FRACS of 268 Macquarie Street, Hobart, certify as follows: 1 I am a Registered Medical Practitioner.

2 I examined Mark Alan Gardner on the 3rd December, 1993.

3 In my opinion, Mr Gardner has wholly recovered from the effects of his acute lower back injury said to have occurred at work on the 14th July, 1993 in respect of which he has been receiving weekly payments of compensation.

4 The grounds upon which I express the opinion are as follows:

On examination he was not distressed. He moved freely and easily without obvious difficulty or discomfort. Examination of the lumbosacral spine showed no visible swelling or deformity and there was no tenderness to palpation of the lumbar spine. There was no evidence of spasm of the paravertebral muscles. Examination of the movements of the lumbosacral spine showed forward flexion to be possible to 85� and the remainder of the movements of the lumbosacral spine were unimpaired. There was no discomfort or pain associated with left and right rotation of the lumbosacral spine and the remainder of the movements of the lumbosacral spine were associated with only minimal discomfort. Neurological examination of the lower limbs showed no significant abnormality. He walked without a detectable limp. He was able to stand on his toes and heels. He was able to bear his full bodyweight on each leg individually and he was able to squat, all without difficulty."

6. On behalf of the appellant it was submitted before the learned Commissioner and on appeal to Crawford J, that the certificate did not entitle the respondent to terminate weekly payments because it did not identify "the effects of the injury" and therefore did not comply with s86(1)(c). The learned Commissioner upheld the submission but Crawford J rejected it. His Honour held that as a matter of law "a certificate which does not identify the effects of the injury in respect of which the payment of weekly compensation is being made, but which adequately identifies the injury itself should not be regarded, for that reason alone and in every case, necessarily invalid for the purposes of s86(1)(c)." In so holding Mr Grueber, for the appellant, contended that Crawford J fell into error. After hearing Mr Grueber, the Court ordered that the appeal be dismissed and said that reasons would be published later. These are my reasons for joining in the order of dismissal. The Workers Compensation Act 1988, s86(1)(c)

7. Termination of weekly payments, pursuant to the Act, s86(1)(c), will not be lawful unless the certificate unambiguously complies with the statutory prescription. See Guthrie Pty Ltd v Sherriff [1994] TASSC 25; (1994) 3 Tas R 399; Burgess v Umina Park Home for the Aged and Anor (1993) 2 Tas R 246.

8. Gibsons Ltd v Jeffrey (1993) 2 Tas R 375, concerned a certificate that simply stated (formal parts omitted): "Re: Grant Jeffrey

This is to certify that I saw and examined Mr Grant Jeffrey on 21/5/91 for the purposes of a medical report. At the conclusion of that examination I formed the opinion that he had substantially recovered from the injury at work on 23/4/90 and was fit to start resuming work."

9. With that certificate, the medical practitioner sent a "medical report" of some length, but neither document referred to the other. The ratio decidendi in Gibsons' case is to be discerned in the following passage in the judgment at 385: "... It is plain, in my opinion, that the certificate of 31 May 1991 from Mr P S H Browne does not comply with s86(1)(a) or s86(2). It is also plain, I think, that the report of 22 May 1991 is not properly to be regarded as a "certificate" at all. It is simply a medical report. But in any event, it is also deficient as a s86(1)(c) certificate as it does not identify the injury in respect of which the workers' compensation payment was being made and does not clearly and unequivocally certify complete or substantial recovery therefrom, or that any ongoing incapacity does not result from the compensable injury.

In my opinion it is not possible to simply read the two documents together for the reasons which I have stated above, but, in any event, it is my opinion that, even if read together, the two documents fail to meet the statutory requirements." There follows this passage in Wright J's reasons for judgment: "Although neither the Act nor rules thereunder prescribe the form which a certificate under s86(1)(c) must take, it should not be too difficult for a competent legal draftsman to draw up a standard certificate for use by medical practitioners which does not fall short of the legal requirements of the Act. Obviously a medical practitioner who is engaged by an employer to examine a worker to ascertain whether or not he has recovered from the compensable injury, need not necessarily have a direct personal knowledge of the injury sustained. Nor is it essential that he has examined the worker on any previous occasion. It is however of fundamental importance that he be accurately and fully acquainted by the employer or some other person with the nature and extent of the injury and the disability in respect of which compensation is being paid and that he reproduce this information in his certificate so that anyone reading that document is able to see at once (1) that he has addressed his mind to the relevant incapacity and (2) that he has expressed his opinion in relation only to that injury and its sequelae. If this is not done the certificate will be fatally deficient."

10. In Lawless v Hazel Bros Pty Ltd A30/1995 and in Hawkins v Mercury Walch Pty Ltd A22/1996 this passage was referred to with approval. In both cases it was accepted by counsel as a correct statement of the law. The passage from the judgment of Wright J does not purport to be a precise definition of the statutory requirements of a valid certificate issued under the first limb of s86(1)(c). Indeed, it is obviously not confined to matters of law. As I read it, that passage in Wright J's judgment is no more than a general statement of what matters of fact ordinarily must be disclosed in a certificate before it can be used by an employer to terminate weekly payments. I doubt if Wright J intended that passage to mean more than that, for in Hawkins he described that passage in his judgment as a "statement of principle" and said: "... it is sufficient compliance with s86(1)(c) if the examining doctor identifies the relevant disabling symptoms with enough clarity and lack of ambiguity to enable a person of reasonable intelligence reading the certificate, to appreciate (a) that it is those symptoms and their disabling consequences which have been accepted by the employer as the foundation for his liability to pay compensation, and (b) that the examining doctor is of the opinion that such symptoms are no longer disabling." The principle to which I understand his Honour was referring in Hawkins is that which is encapsulated in the closing words of the passage cited from Gibsons' case viz, "anyone reading that document (the certificate) (must be) able to see at once (1) that he has addressed his mind to the relevant incapacity and (2) that he has expressed his opinion in relation only to that injury and its sequelae." Whether there has been compliance with the statutory prescription is a question of fact in each case. In the passage from Gibson's case cited above I do not understand Wright J to be stipulating as a matter of law that in each case, the certificate must set out the nature and extent of the injury and the disability in respect of which compensation is being paid. As Crawford J observed in this case, the statute does not so provide and the authorities upon which Wright J relied, Vurlow v Leighton Nursing Homes (1978) WAR 15; Sadler v Femfield Pty Ltd Western Australian Supreme Court unreported No 9047A, do not support such a wide proposition.

11. In Hawkins v Mercury Walch Pty Ltd (supra) the certificate relevantly provided: "(The worker) told me that, on the 30th March 1993 as she was walking out of the factory she noticed a sharp pain over the dorso-lateral aspect of her left wrist. (Hereinafter referred to as the 'injury')." It was argued that the certificate did not comply because it only referred to symptoms from an injury and thereby failed to identify the relevant injury. In Hawkins there was no suggestion that the certificate did not adequately refer to the effects of the injury. It clearly did. The only issue in that case was whether the certificate complied with the statute by describing the injury, not by any diagnostic label but by reference to the day and place of occurrence and the symptoms it generated. In this context my reasons for judgment, with which the other members of the Court were in substantial agreement, referred with approval to the above cited passage from the judgment of Wright J in Gibsons' case. The purpose in doing so was to show that the certificate in question made it clear that the certifier had addressed his mind to the relevant injury being the one "in respect of which payment is being made". I said at 3: "... to be valid, a certificate must concern itself with the injury as well as the effects of the injury in respect of which compensation is being paid." I added at 4: "What matters is whether, in an ordinary common sense way, the certificate identifies the injury in respect of which the weekly payment is being made, the effects of that injury and certifies that the worker has wholly or substantially recovered from those effects".

12. Emphasis is to be placed on the need to construe certificates purportedly issued pursuant to the first limb of s86(1)(c) in a plain common sense way. The words used by certifying medical practitioners should not be subjected to the kind of scrutiny that an equity lawyer might give precatory words in an old will to see if they create a valid trust. In Hawkins it was not contended that the certificate did not sufficiently refer to the effects of the injury nor that it failed to certify that there had been the relevant recovery from the relevant injury. The passages from Hawkins cited above are to be read in the factual context in which they were used. They are not authority for the proposition that the validity of a certificate depends (inter alia) on identification of the effects of the relevant injury for, as Crawford J points out, the statute does not so provide. Statutory prescription for a valid certificate that purports to rely on the first limb of s86(1)(c) is as follows: (a) it must be made by an accredited medical practitioner who has examined the worker; (b) it must certify that the practitioner's opinion is: (i) that the worker has wholly recovered or substantially recovered from the effects of the injury in respect of which payment is being made; or (ii) that the worker's incapacity is no longer due, wholly or substantially, to that injury;

(c) it must specify the grounds upon which the expressed opinion is given.

13. What appears to be a growing tendency in some parts of the legal profession to construe these certificates as if they were testamentary instruments or statutes needs to be discouraged. That is contrary to the intention of Parliament. The words of s86(1)(c) and (2) are simply expressed and no curial gloss should be placed upon them. I agree with Crawford J when he said in the court below, that "it is important in the interests of the parties, and therefore the public that technical difficulties should not be created."

14. In Lawless v Hazell Bros Pty Limited (supra), Zeeman J held that the certificate in that case identified a traumatic event but did not identify any injury. The first limb of s86(1)(c) does not use the word "identify". The statutory requirement is certification of one or more of the prescribed sequelae of the "injury in respect of which the payment is being made". There must be compliance with that requirement in an unambiguous way. To that extent, the relevant injury must be "identified". As I understand his Honour's reasons for judgment in Lawless, he was of the opinion that the certificate in that case failed to unambiguously refer to the injury in respect of which the payment was being made in the sense that no Commissioner could reasonably have found that it did so refer to that injury. On the same basis, his Honour also held that the certificate did not comply with s86(1)(c) because it certified that no incapacity had ever arisen from whatever injury, if any, the appellant suffered in the first place and certification of that kind is not contemplated by s86(1)(c).

15. At 3 of his reasons for judgment in Lawless, Zeeman J set out the passage from the judgment of Wright J in Gibsons Limited v Jeffrey (supra) that is set out earlier in these reasons. His Honour's understanding of that passage differs from mine. Zeeman J said, also at 3: "As I understand that passage, Wright J was referring to the first limb of s86(1)(c). At the very least his Honour is to be taken as having held that before an employer may terminate a weekly payment as a consequence of a certificate which relies on that limb, the certificate must identify the injury in respect of which the weekly payment sought to be terminated is being paid, identify the effects of that injury and certify that the worker has wholly or substantially recovered from those effects. With respect I agree that a certificate which does not comply with such requirements does not satisfy the requirements of the first limb of s86(1)(c)."

16. With great respect to Zeeman J, I find myself unable to agree with the views expressed in that passage if they purport to express the intention of Parliament by the enactment of the first limb of s86(1)(c). Such an interpretation is not authorised by the words of the statute. It may be that in many cases, if his Honour's directions are not followed, the result will be a certificate that does not unambiguously certify the appropriate recovery from the effects of the relevant injury but, in my respectful opinion, it is not open to the Court to specify requirements that are not specified by the statute. Conclusion

17. I agree with Crawford J that in this case error occurred in the learned Commissioner ruling, as a matter of law, that a certificate which fails to identify the effects of an injury is necessarily not a certificate within the meaning of s86(1)(c).

SLICER J The issue raised by the appellant is whether a certificate issued pursuant to the Workers Rehabilitation and Compensation Act 1988, s86(1)(c) ("the Act") has effect only if it sets out the "effect of the injury" from which the worker is said to have wholly or substantially recovered. The Act, s86(1)(c), as of the relevant time, permitted an employer to terminate or reduce a weekly payment where: "(c) a medical practitioner who has examined the worker has certified that, in his opinion, the worker has wholly recovered or substantially recovered, from the effects of the injury in respect of which the payment is being made or that the worker's incapacity is no longer due, wholly or substantially, to that injury;"

2. The appellant's notice of appeal claims: "1 That his Honour erred in law in holding that Dr Roth's certificate complied with the requirements of section 86 (1) 31. of the Workers Rehabilitation and Compensation Act 1988 notwithstanding that it did not identify the effects of the injury in respect of which the weekly payment of compensation was being made.

2 That his Honour erred in law in holding that Dr Roth's certificate complied with the requirements of section 86 (1) 32. of the Workers Rehabilitation and Compensation Act, 1988".

3. The medical certificate states: "I, Dr J L Roth, FRACS of 268 Macquarie Street, Hobart, certify as follows: "I, Dr J L Roth, FRACS of 268 Macquarie Street, Hobart, certify as follows: 1 I am a Registered Medical Practitioner.

2 I examined Mark Alan Gardner on the 3rd December, 1993.

3 In my opinion, Mr Gardner has wholly recovered from the effects of his acute lower back injury said to have occurred at work on the 14th July, 1993 in respect of which he has been receiving weekly payments of compensation.

4. The grounds upon which I express the opinion are as follows:

On examination he was not distressed. He moved freely and easily without obvious difficulty or discomfort. Examination of the lumbosacral spine showed no visible swelling or deformity and there was no tenderness to palpation of the lumbar spine. There was no evidence of spasm of the paravertebral muscles. Examination of the movements of the lumbosacral spine showed forward flexion to be possible to 85� and the remainder of the movements of the lumbosacral spine were unimpaired. There was no discomfort or pain associated with left and right rotation of the lumbosacral spine and the remainder of the movements of the lumbosacral spine were associated with only minimal discomfort. Neurological examination of the lower limbs showed no significant abnormality. He walked without a detectable limp. He was able to stand on his toes and heels. He was able to bear his full bodyweight on each leg individually and he was able to squat, all without difficulty."

4. The appellant contends that a reading of statements made by judges of this Court in Gibsons Ltd v Jeffrey (1993) 2 Tas R 375; Lawless v Hazell Bros Pty Ltd, A30/1995 and Hawkins v Mercury Walch Pty Ltd, A22/1996, requires the effects of the injury to be identified and specified by the maker of a certificate pursuant to the Act, s86(1)(c). An examination of those authorities does not warrant such conclusion. In Gibsons Ltd v Jeffrey (supra) Wright J, having considered the import of decisions concerning the Workers Compensation Act 1912 - 1975 (WA), s12B(1) stated at 5: "Although neither the Act nor rules thereunder prescribe the form which a certificate under s86(1)(c) must take, it should not be too difficult for a competent legal draftsman to draw up a standard certificate for use by medical practitioners which does not fall short of the legal requirements of the Act. Obviously a medical practitioner who is engaged by an employer to examine a worker to ascertain whether or not he has recovered from the compensable injury, need not necessarily have a direct personal knowledge of the injury sustained. Nor is it essential that he has examined the worker on any previous occasion. It is however of fundamental importance that he be accurately and fully acquainted by the employer or some other person with the nature and extent of the injury and the disability in respect of which compensation is being paid and that he reproduce this information in his certificate so that anyone reading that document is able to see at once (1) that he has addressed his mind to the relevant incapacity and (2) that he has expressed his opinion in relation only to that injury and its sequelae. If this is not done the certificate will be fatally deficient." That statement was considered by Zeeman J in Lawless v Hazell Bros Pty Ltd (supra) who believed that: "As I understand that passage, Wright J was referring to the first limb of s86(1)(c). At the very least his Honour is to be taken as having held that before an employer may terminate a weekly payment as a consequence of a certificate which relies on that limb, the certificate must identify the injury in respect of which the weekly payment sought to be terminated is being paid, identify the effects of that injury and certify that the worker has wholly or substantially recovered from those effects. With respect I agree that a certificate which does not comply with such requirements does not satisfy the requirements of the first limb of s86(1)(c)." It was this observation which led the learned Commissioner to determine that the certificate was deficient. In Hawkins v Mercury Walch Pty Ltd (supra), Underwood J at 3 noted that the passage in Gibsons Ltd v Jeffrey (supra) had been accepted by counsel for both parties appearing before the Full Court as "a correct statement of the law" and agreed that the "certificate must concern itself with the injury as well as the effects of the injury in respect of which compensation is being paid" and "that the certificate must clearly and unambiguously identify the relevant injury ... in respect of which payments of compensation are being made".

The contention advanced on behalf of the appellant is an example of attempted continued refinement of an original general proposition. In Gibsons Ltd v Jeffrey (supra) Wright J held that certificates which did not identify the injury do not comply with the statutory requirement. His obiter dictum related to a practical suggestion as to how any confusion concerning the matter addressed by the medical practitioner might be addressed. The statement quite properly concerned the difficulty of certification in cases where there may be differing injuries and sequelae, not all of which were relevant to the payment of workers compensation. His Honour had determined that one of the two certificates involved in the matter under consideration was invalid because it made no reference at all to the original injury and that the second, and more comprehensive, medical report did not, on its face, purport to be a certificate at all. It was in this context that Wright J proffered some advice to employers as to the practical manner in which compliance could be effected. In Lawless v Hazell Bros Pty Ltd (supra) Zeeman J was concerned with a certificate which purported to identify the original injury as a hit to the head. Such could never be classified as an identification of injury. Further, the opinion expressed in the certificate was, "that the work accident is not responsible for the symptoms ... complain(ed) of and that he has wholly recovered from the effects of the injury ...". As Zeeman J said, the real claim of the certificate was that "a weekly payment ought never have been made" and the employer ought to have sought redress by means of the Act s81A(5). It is in the context of identification of the original injury that his Honour's comments must be considered. Reliance on the observations of Underwood J in Hawkins v Mercury Walch Pty Ltd (supra) overlooks the statement of principle made by his Honour at 4 that: "What matters is whether, in an ordinary common sense way, the certificate identifies the injury in respect of which the weekly payment is being made, the effects of that injury and certifies that the worker has wholly or substantially recovered from those effects. I do not understand Lawless to be authority for the general proposition that an injury cannot be sufficiently identified by reference to symptoms. That is not to say that reference to symptoms alone will necessarily be sufficient identification. Each case will turn upon its own facts of course. The Act is not concerned with technicalities." In his reasons for judgment given in the same case Wright J stated: "In my opinion, whether or not the injury or disease producing incapacitating symptoms is capable of being affirmatively identified by some generic label, it is sufficient compliance with s86(1)(c) if the examining doctor identifies the relevant disabling symptoms with enough clarity and lack of ambiguity to enable a person of reasonable intelligence reading the certificate, to appreciate (a) that it is those symptoms and their disabling consequences which have been accepted by the employer as the foundation for his liability to pay compensation, and (b) that the examining doctor is of the opinion that such symptoms are no longer disabling." His Honour's comments are directed at the effect of the totality of the certificate. If the certificate provides a nexus between the condition for which compensation is paid and the opinion of the examining doctor that such condition is no longer in existence, then the criteria predicated by statute are met.

5. There are practical problems if the approach sought by the appellant is applied to a certificate made pursuant to the Act, s86(1)(c). The medical practitioner may be unable to identify a precise source from which his information is derived. In many instances the original certificate is devoid of description of either the diagnosed injury or its sequelae. An inaccurate account may be provided by the patient. Original symptoms may have been exacerbated or abated which would cause difficulty in the time at which the effects must be specified. In many cases effects are varied and can be interdependent and it would prove impossible to identify them all. The Act requires the certificate to state an opinion of recovery from that condition for which compensation was originally paid. An examination of the certificate must disclose a nexus between recovery and some identifiable condition, the existence of which warranted the payment of compensation. The condition may be the existence of a diagnosed injury but where such is not possible or has not been sufficiently diagnosed, then it is the manifestation of that injury. The maker of the certificate is required to state a link between his opinion and the earlier condition and need not spell out in compendious form the description of symptoms and the like. In this case the certificate referred to "the effects of ... acute lower back injury". Counsel for the appellant suggested, in the course of argument, that there would be sufficient compliance with the statute if the word "painful" was included in the description. The suggestion indicates the weakness of the argument. Presumably, it was a disabling effect of the lower back injury which prevented the appellant from continuing with his employment and warranted the payment of compensation. But the manifestation of the injury may have been stiffness, restriction of movement, pain and the like. There may well be no "single" effect. In par4 of the certificate the examining medical practitioner explored all possible continued existence of injury and manifestation. The examination was concerned with the possible continuing effects of a condition existent in July 1993. It disclosed a nexus between the opinion of recovery and the original condition giving rise to the payment of compensation. I agree with the conclusion of the learned primary judge (A26/1996) at 7 that: "... a certificate which does not identify the effects of the injury in respect of which the payment of weekly compensation is being made, but which adequately identifies the injury itself, should not be regarded, for that reason alone and in every case, as necessarily invalid for the purposes of s86(1)(c)."

6. It was for these reasons that I joined in the order of the Court dismissing the appeal.