Written submissions dated 19 January 2026, 28 January 2026 and 4 February 2026.

Weekly payments of compensation and the cost of benefits payable under Division 2 of Part VI of the Workers Rehabilitation and Compensation Act 1988 are not to be paid by the employer.

Workers Compensation - Section 81A - Nature of referral - Sufficiency of reasons for dispute - Facts and evidence.

Workers Rehabilitation and Compensation Act 1988; ss 3, 25, 37, 38, 42, 81A.

Candice Care Inc. v S [2021] TASWRCT 20;

State of Tasmania (Department of Education) v B [2022] TASCAT 58;

St Helens Oysters Pty Ltd v Coatsworth [2007] TASSC 90;

Bradshaw v Tasmania Networks Pty Ltd [2020] TASFC 2;

Vos Construction & Joinery Pty Ltd v Norton-Smith [2016] TASSC 38;

Tassal Operations Pty Ltd v Lese [2021] TASSC 22;

The State of Tasmania (Department of Natural Resources and Environment) v R [2024] TASCAT 84;

M v Allianz Australia Services Pty Ltd No. 2 [2019] TASWRCT 35;

Karinya Young Women's Service Inc v W [2023] TASCAT 36;

Alison Jane Connolly v P and O Resorts Pty Ltd t/as Cradle Mountain Lodge [1996] TASSC 132;

Lamont v MRD Supermarkets Pty Ltd [2016] TASSC 16.

This decision has been anonymised for the purposes of publication.

1. The worker made a claim for compensation on 1 October 2025 for an alleged workplace injury occurring on 4 September of 2025. The employer has disputed liability to pay compensation to the worker pursuant to s 81A of the Workers Rehabilitation and Compensation Act 1988 (WRC Act). Where an employer disputes liability for a claim pursuant to s 81A of the WRC Act, the employer must establish that they have a reasonably arguable case to do so. If the Tribunal finds that a reasonably arguable case exists, it must make orders pursuant to s 81A(3)(c) and (d) of the WRC Act to the effect that compensation is not to be paid to the worker.
2. The two issues to be determined in this referral are whether;

(i) the Tribunal has jurisdiction to deal with this s 81A referral; and if so,

(ii) the employer has discharged its onus to prove a reasonably arguable case to dispute its liability to pay compensation to the worker.

1. Subsequent to the worker's lodgement of her workers compensation claim pursuant to s 81A of the WRC Act, the employer disputed its liability to pay compensation to the worker.
2. In its referral to the Tribunal on 16 December 2025, the employer pleaded three grounds of dispute asserting that there was sufficient evidence before the Tribunal for it to find a reasonably arguable case to dispute its liability to pay compensation to the worker. The three grounds of dispute were:

(a) A factual dispute;

(b) A dispute that causation can be attributed to the requisite degree to the worker's employment; and

(c) A potential defence to liability pursuant to s 25(1A) of the WRC Act.

1. In support of its referral, the employer relied upon the following:

(i) Statement - TG signed 12 December 2025 with attachments:

• Worker - Teams Chat
• Incident notification
• Letter Aboriginal Health Service
• Email attaching Authority to Release Information Agreement
• Aboriginal Health Service medical certificate 17 September 2025
• Aboriginal Health Service medical certificate 23 September 2025
• Email [worker] to TasWater attaching initial WCMC
• Initial WCMC
• Claim form worker section
• Claim form employer's section
• Statement of worker
• CS Hub - Teams chat
• Stacey - Teams chat
• Worker - End of year PDA discussion notes
• Managing Work Stress document
• FW PDA Creation for worker - Action required

(ii) Section 81A letter to the worker disputing liability with enclosures.

1. The s 81A referral hearing was initially listed before the Tribunal on 20 January 2026 but on 19 January 2026 solicitors for the worker provided to the Tribunal and the employer's solicitors extensive written submissions opposing the employer's s 81A referral.
2. In the initial hearing of the s 81A referral on 20 January 2026, directions were made giving the employer an opportunity to provide written submissions in response to the worker's solicitor's written submissions of 19 January 2026.
3. In accordance with those directions, on 28 January 2026 the employer's solicitor provided their written submissions and in further compliance with the directions of 20 January 2026, on 4 February 2026 the worker's solicitor provided a reply to the employer's written submissions of 28 January 2026.
4. As a consequence of the worker's solicitor in their reply submissions of 4 February 2026 raising a jurisdictional issue, to accord procedural fairness to the employer's solicitor they were offered a further opportunity to provide a written response in relation to the worker's reply submissions.
5. On 11 February 2026, the employer's solicitor indicated that they did not wish to make any further written submissions. They further advised that they did not agree with the worker's submissions or concede they were correct.
6. Subsequent to a request from the Tribunal to the parties in an effort to determine whether or not they were content for the determination of this matter to occur on the basis of the evidence and written submissions before it, by 17 February 2026 the worker's solicitor and employer's solicitor indicated they were content for the Tribunal to take that course.

1. The worker appears to assert that the Tribunal is without jurisdiction to hear the employer's s 81A referral as the employer has not complied with his obligations to "inform the worker" of the reasons for disputing liability as required by s 81A(1)(b) of the WRC Act.
2. Section 81A(1)(b) relevantly states:

81A. Disputes of liability for weekly payments and other benefits > > (1) An employer who disputes liability to pay compensation by way of weekly payments for an injury referred to in section 81(1) or benefits under Division 2 of Part VI must, within 84 days of receiving the claim for compensation in respect of the injury to the worker - > > (a) serve the worker with written notice that the employer disputes liability - > > (i) to pay compensation by way of weekly payments; or > > (ii) to pay any benefits payable under Division 2 of Part VI in respect of the injury; and > > (b) inform the worker of the reasons for disputing liability; ...

3. In support of this contention, the worker relies upon the decision of Commissioner Wilkins (as she then was) in Candice Care Inc v S [2021] TASWRCT 20.
4. The worker specifically relies on [51]-[53] where it was stated:

The Act requires that an employer who disputes liability to pay compensation must serve a worker with, not only notice that it disputes liability - s81A(1)(a), but also inform the worker of the reasons for disputing liability - s81A(1)(b), and provide to the worker all evidentiary material upon which the employer intends to rely. It is clear that what the employer is required to provide to the worker within the statutory time limit is more than simply information that the claim is in dispute. > > In the present instance, as a result of the participation by the worker and his counsel in the hearing of the s81A referral as it has unfolded to date, I am prepared to draw the inference that the worker was aware that his claim for compensation has been disputed, and was so aware prior to the expiration of the 84 days (the first appearance in relation to the s81A referral occurring within the 84 days). However, there is no evidence that the correspondence from the employer's solicitors to the worker's solicitors came into the possession of the worker, nor that he became aware of any of the details of the dispute within the statutory time frame of 84 days from the date the claim was made. > > Although I have already determined that the worker was not served with the dispute, because service via email was not available to the employer, even if I am wrong about that, there is no evidence that notice of the dispute, as contemplated by s81A, including the reasons for the dispute, came into the possession, or to the attention, of the worker within the 84 days permitted by s81A. On that basis, the Tribunal does not have jurisdiction to hear the s81A referral.

5. The worker places significant reliance on [53] and contends that this paragraph lends support to the view that the failure to provide adequate reasons is a jurisdictional issue.
6. The worker further states that this requirement is purposive and that it must exist to require the employer to provide such information to the worker so that the worker can be reasonably expected to understand the basis of the dispute. The worker says it need not be delivered in terms such that anyone might understand it, the WRC Act is after all complex, but it must be clearly intelligible to someone with familiarity with the workers compensation scheme with the minimum requirement being a clearly articulated reason that can be assessed by the worker (with legal assistance if appropriate).
7. In conclusion, the worker asserts that they must be placed in a position to consider the merits of the employer's dispute relative to the relevant sections of the WRC Act - ss 81A, 25(1A), 37, 38 etc. It therefore follows inevitably that the employer must explain itself such that the claims can be readily understood by reading the notice, and if it is incorporated, the referral.
8. Despite being offered the opportunity to respond to the worker's submissions in regard to this issue, the employer advised on 11 February 2026 that it did not intend to file further submissions.
9. Having considered the notice to the worker from the employer dated 11 December 2025, the reasons for disputing the worker's claim are clearly articulated as: "there is a factual dispute in relation to your claim. We are in receipt of evidence from your employer which denies and/or places into dispute the alleged causes of your claimed condition. On that basis, it is reasonably arguable that you have not suffered..."
10. Further in the notice to the worker, the employer states: "further and in the alternative, if you have suffered an injury or disease that is an illness of the mind or disorder of the mind (which is not conceded) then it is reasonably arguable that this has arisen substantially from..."
11. In my view, this clearly sets out the reasons for the dispute. Those reasons have clearly been pursued by the employer in the s 81A referral with significant of the evidentiary basis for those reasons for disputing the worker's claim being set out within the referral.
12. I am satisfied that the employer has complied with s 81A(1)(b) of the WRC Act in informing the worker of the reasons for disputing liability and that I thus have jurisdiction to hear this referral. I am emboldened in this regard by my consideration of the decision of Senior Member Jack in State of Tasmania (Department of Education) v B [2022] TASCAT 58 delivered on 8 June 2022.

1. The test for whether a reasonably arguable case exists is well settled, and as is detailed in St Helens Oysters Pty Ltd v Coatsworth [2007] TASSC 90 at [10], Evans J stated:

A case will not be reasonably arguable unless the case itself is reasonable in a sense that there is a reasonable prospect of the claim being rejected following a final hearing...The very notion of a "reasonably arguable case", like the very notion of a "prima facie case', precludes a final determination of a disputed question of fact...On the face of a s 81A, a reasonably arguable case will exist concerning the liability of an employer to pay a worker if it is reasonably arguable on the material in relation to the claim or identified deficiencies or weaknesses in the claim that, following a contested hearing, it may be rejected.

2. Another formulation of this test was detailed in the Full Court decision of Bradshaw v Tasmania Networks Pty Ltd [2020] TASFC 2, where Estcourt J at [17] stated as follows:

Whilst the employer carries the onus of proof on a s 81A application, I accept the submission ... that what the employer is required to prove is not that there is no liability under s 25 of the Act, but only that there exists, on the evidentiary material that the employer relies upon in the s 81A proceedings, a reasonable chance that the worker will be unable to discharge the onus of proof that will ultimately rest with the worker by virtue of the Act, s 49(2)(a), on a final hearing of the worker's claim. As counsel for the employer put it, "the worker was certainly not required in this instance to positively prove that some specific factor other than the worker's employment was the major or most significant contributing factor".

3. As was stated in Vos Construction & Joinery Pty Ltd v Norton-Smith [2016] TASSC 38, the employer's case need not be strong nor compelling, but must at least be reasonably arguable.
4. In Tassal Operations Pty Ltd v Lese [2021] TASSC 22, Pearce J at [8] stated the following:

The Act does not require that the employer's case about liability be strong or compelling, but the case that the claim may ultimately be rejected must be reasonably arguable.

5. Following this reasoning, Senior Member Jack in The State of Tasmania (Department of Natural Resources and Environment) v R [2024] TASCAT 84 at [23] stated the following:

In determining whether an employer has demonstrated the existence of a reasonably arguable case to dispute a worker's claim for compensation, the Tribunal takes the evidence relied upon by the employer at its highest.

6. From these authorities, it is clear that it is not the Tribunal's role when dealing with a s 81A referral to make findings of disputed facts. That is to occur upon the hearing of any s 42 application made by the worker if a reasonably arguable case is found. The Tribunal's role in a s 81A referral is to determine on the evidentiary material before it in accordance with the formulations detailed above, whether there is a reasonably arguable case to dispute liability to pay compensation to the worker.

1. The employer says that there is a clear factual dispute in relation to this claim when consideration is given to the contents of the worker's claim form of 1 October 2025 and the initial worker's compensation medical certificate dated 29 September 2025.
2. The employer relies upon the statement of TG which the employer says clearly places into dispute the alleged factual basis of the worker's claim.
3. The employer says that whilst it does not dispute that the worker took a call which she has identified as distressing on 4 September 2025, the employer has detailed through the statement of TG what it says it knows about the call and two subsequent calls. The employer asserts that the factual dispute arises in the context in which the call and the worker's alleged injury took place.
4. The employer's evidence contradicts the worker's evidence regarding the extensive training and coaching that she had been engaged in and had been provided with. The employer also identified that the worker had been offered but had declined further development opportunities.
5. The employer submits that whilst its evidence does not dispute the occurrence of the telephone call of 4 September 2025 per se, it does cast doubt on the worker's version of events and highlights that the Tribunal cannot accept what the worker says about her injury and the cause of it on face value.
6. The employer properly concedes that this is not to put the worker to proof but asserts it does highlight the potential deficiency in her evidence, noting that the causative role of any factor must invariably turn upon the adjudicator's assessment of the veracity and reliability of the complainant.
7. With regard to causation, the employer submits that although there is no independent medical evidence before the Tribunal as to the symptoms or causation of Bipolar II, there is evidence of the worker's admission of this as a pre-existing condition, and it is therefore possible that the worker is suffering from a pre-existing condition or that the pre-existing condition is a substantial cause of her incapacity, with the employment playing a minor role.
8. The employer submits that the certified claimed condition of an adjustment disorder by definition indicates an adjustment disorder manifests within three months of a stressor (or stressors).
9. The employer then goes on to state multiple potential stressors temporal to her claim that could give rise to such a diagnosis leading to incapacity, these being:

The worker was counselled early on about her unplanned leave and potential performance outcomes of continued unplanned leave. > > The worker experienced the relocation of her child to another jurisdiction in 2025. > > The worker advised ADHD (unmedicated) in March 2025, was awaiting psychiatric input, and sought workplace and workload adjustments to reduce hours of work downwards as it was impacting her ability to work. > > In April 2025, the worker advised she had returned a positive result for cervical cancer screening. > > In May 2025, the worker was experiencing back pain and took leave. > > In June 2025, the worker advised psychological abuse by her ex-partner. > > In late June-early July 2025, the worker advised that she was involved in family law proceedings. > > In late June-early July 2025, the worker averted to family violence. > > The worker experienced pregnancy loss in July 2025 and arrived at the office in distress and was sent home. > > In mid-July 2025, the worker posted to her social media profiles with comments suggesting a 'black heart' and 'giving up' and confided in her manager about personal relationship issues. > > In late July 2025 the worker was tearful and distressed in the workplace due to a failed motion at a southern Tasmanian council. > > In late July 2025, the worker's significant pattern of workplace absences and concerns around her wellbeing were directly discussed during a performance review. The worker explained that she was still in recovery after a difficult period in her personal life, and that the ongoing efforts to develop a suitable care and treatment plan for her ADHD were causing a difficulty in meeting deadlines and staying on top of her work. She remarked that she was currently working at about half capacity due to recent emotional turmoil and health issues. > > In August 2025 the worker sought further guidance and strategies to manage her ADHD and advised the employer she had another psychiatrist appointment coming up.

10. With regard to the defences pursuant to s 25(1A) of the WRC Act, the employer submits that it has identified aspects of performance management or reasonable administrative action that caused the worker distress and may be causative of her condition. In this regard, the worker relied on the evidence of TG to support:

(a) Multiple discussions around disruptive behaviour in the workplace;

(b) The contents of the performance review discussion on 28 July 2025;

(c) The worker expressed on multiple occasions her sadness and distress and was tearful in the workplace, due to being denied the opportunity to participate in a project of cultural significance to her because her work attendance and wellbeing due to external stressors and mental health concerns was not up to standard.

1. In her written submissions the worker asserts that a core weakness in the employer's case is that no plausible alternative explanation for incapacity is proffered.
2. The worker asserts that it is not in dispute:
   • That the causative incident on 4 September occurred;
   • The nature of that incident (a call involving a distress and difficult customer expressing suicidal ideation); or
   • The temporal connection between the incident and the worker's psychological decompensation (incapacity).
3. The worker asserts that the employer relies on scattered hearsay references to unrelated everyday life stressors, historical health and person matters that are unrelated to the undisputed 4 September 2025 incident, and assertions about training and workplace support that appear to seek to attribute blame for the injury, which is not relevant.
4. The worker asserts that none of the material provided which is capable of being accepted as evidence, even if taken at its highest, provides a plausible alternative explanation as to why the worker became incapacitated when she did immediately following the uncontested incident of 4 September 2025.
5. The worker also submits that the multifactorial nature of psychological injuries does not assist the employer in making out an alternative cause. The worker properly states that this proposition is uncontroversial, but asserts that it does not advance the employer's case. The worker submits that the evidence about the life stressors in her personal life does not:
   • Disentitle a worker from compensation for an undisputed work incident on 4 September 2025; or
   • Negate causation; or
   • Establish that employment was not the substantial contributing factor.
6. The worker submits that in the circumstances where:
   • The incident of 4 September 2025 is not genuinely disputed;
   • It involved an exposure to actual suicidal ideation as particularised in the referral; and
   • The medical evidence attributed incapacity to that incident,

the employer's reliance on vague domestic stressors is incapable of displacing work causation even on a provisional basis.

1. The worker asserts that the employer's evidence establishes that immediately after the 4 September incident, the worker was impacted in the performance of her duties, those duties were modified to be easier for her and she sought medical attention arranging a GP appointment for 9 September which lead to an initial three days off work based on "a distressing incident at work". Nothing else the employer put forward is inconsistent with this.
2. The worker submits that the training and support evidence proffered by the employer is irrelevant to causation, with the worker asserting that none of the material addresses the statutory question whether employment was a substantial contributing factor to the worker's injury, and the fact that the employer provided training and support does not mean that:
   • An injury did not occur; or
   • Exposure to traumatic material was non-injurious.
3. The worker submits that to the extent the employer suggests that the worker failed to follow training or protocol, the worker submits that suggestion:
   • Is not clearly articulated;
   • Is not supported by any expert evidence;
   • Most importantly is not relevant to the legal test.
4. The worker submits that those matters are irrelevant to the s 81A threshold and do not advance a reasonably arguable case.
5. The worker asserts that no factual dispute of substance with the Tribunal being left to ask the question "what exactly is the factual dispute?".
6. The worker submits that the referral simply constitutes a general denial which is not supported by a competing factual narrative and therefore cannot constitute a reasonably arguable case.
7. The worker cites Vos Construction & Joinery v Norton-Smith (supra) at [5] where it was stated:

It is not enough in a s 81A referral for the employer to indicate that it simply wishes to put the worker to proof. The terms and history of s 81A disclose a legislative intention that an employer must do more than rely on the contention that a worker may not ultimately be able to discharge the onus of proof, in support of its contention that a mere denial of the worker's claim is not sufficient.

8. In response to the employer's assertion of the availability of the defences pursuant to s 25(1A) of the WRC Act, the employer asserts that reasonable administrative action is not made out, as the employer has not discharged its onus to provide submissions as to a specific action or actions of the employer said to be capable of satisfying s 81A, the specific ground it relies upon, and how it says that the ground may be satisfied.
9. I have already determined that the employer has informed the worker of the basis of the employer's case regarding the defences pursuant to s 25(1A) under the jurisdiction heading of this decision.
10. The worker however contends that although the employer has referenced the basis for this ground of dispute in paragraph 80 and onwards of the statement of TG, none of this identifies a specific action of the employer to satisfy the test in s 25(1A).
11. The worker asserts that on the referral:
    • No specific administrative action is identified as causative;
    • No causative element is identified;
    • The medical evidence attributes the condition to the incident of 4 September 2025;
    • It is not possible to derive from the referral what the nature of the employer's dispute is, what evidence it is based on, or why it is said to be incompatible with liability;
    • A build up of stressful circumstances prior to a major stressor is not inconsistent with liability.
12. The worker submits that the reasonable administrative action exclusion is therefore unsupported by the evidence in the referral and is incapable of defeating liability.
13. In summary, the worker submits that the employer has failed to establish a reasonably arguable case because:
    • The dispute, to the extent it is particularised, is purely speculative;
    • The evidence relied upon is largely hearsay, irrelevant, or mere inuendo and speculation (and thus not evidence);
    • No plausible alternative explanation for incapacity was advanced on the employer's evidence;
    • The material relied upon cannot, even if accepted, defeat liability;
    • The referral amounts to little more than "we disagree".

1. Having considered the evidence provided by the employer in support of its s 81A referral, and the worker's evidence and submissions, and noting that there is no dispute about the actual occurrence of the purportedly causative phone call of 4 September 2025, I accept the employer's submissions that although there is no doubt about the occurrence of this phone call per se, the employer's evidence does go to the context of this telephone call and thus casts some doubt on the worker's version of events.
2. It is the worker's evidence that she had not been provided with formal training in mental health responses - not even basic first aid for psychological emergencies - and was completely unprepared. She further alleged that she was "severely underqualified to manage such a situation" and further infers that there had been no proper training.
3. The employer's evidence sets out the worker's occupational history relevant to the role she was undertaking at the relevant time, and in particular the extensive training and coaching that she had been engaged in and had been provided with. The employer's evidence also identified that the worker had been offered but had declined further development opportunities.
4. The employer has conceded that it is not to put the worker to proof but that this evidence does highlight a potential deficiency in her evidence that the causative role of any factor must invariably turn upon an adjudicator's assessment of the veracity and reliability of the complainant.
5. I am satisfied that with regard to this ground of dispute the employer has discharged its onus to establish the existence of a reasonably arguable case.
6. With regard to issues of causation, the employer has referred to the evidence of TC to support its contention that there is significant evidence of multiple stressors external to the worker's workplace that could be causative or contributing to (either alone or in concert) the worker's claimed condition and incapacity as well as identifying already reduced capacity of the worker by reason of mental health and admissions by the worker that she was experiencing distress and was only working at 50% capacity due to factors external to the workplace.
7. In my view, the evidence relied upon in this regard is sufficiently temporal, the last being in late July of 2025, and thus has the potential to provide a plausible alternative cause and may affect a finding that the incident relied upon by the worker being the telephone call on 4 September 2025 was the major or most significant cause of her incapacity.
8. Additionally, on the worker's own evidence, she has a pre-existing diagnosis of bipolar. With symptoms diagnosed as "mood disorder", and a provisional diagnosis of an adjustment disorder with mixed anxiety and depressive symptoms, articulated in the initial prescribed medical certificate of 29 September 2025 (following three non-prescribed certificates). With it being known that an adjustment disorder can manifest within three months of the occurrence of stress or stressors, further potential doubt is cast on the phone call of 4 September 2025 being the most significant cause of the worker's incapacity.
9. Further support of a reasonably arguable case in this context is the authority to support the contention that workers compensation certificates do not deal with causation - see [11] of Evan J's decision in St Helens Oysters v Coatsworth (supra) where it was stated:

...that the information required by a workers compensation medical certificate does not include an opinion as to whether the worker's disease arose out of and in the course of his employment, and to which his employment contributed to a substantial degree - s 25(1)(b).

10. Also see [9] of Senior Member Jack's decision in Karinya Young Women's Service Inc v W [2023] TASCAT 36.
11. I am satisfied on all of the evidence that the employer with regard to this ground of dispute, has discharged its onus of establishing a reasonably arguable case.
12. With regard to the employer's dispute of the worker's claim on the basis of the defences available pursuant to s 25(1A)(a), (b), (d), I am satisfied that the employer has discharged its onus of proof to establish a reasonably arguable case as the employer has identified aspects of performance management or reasonable administrative action that caused the worker distress may be causative of her condition. These were identified as:

(a) Multiple discussions around disrupting behaviours in the workplace; and

(b) The contents of performance review discussion on 28 July 2025; and

(c) The worker expressed on multiple occasions her sadness and distress and was tearful in the workplace due to being denied the opportunity to participate in a project of cultural significance to her because her work related attendance and wellbeing due to external stressors and relevant health concerns were not up to standard.

1. In my view, it is reasonably arguable that these actions could be found to be reasonable administrative action taken in a reasonable manner.
2. It is trite that determinations in this regard both to their nature and effect and their causal involvement in a worker's incapacity are not matters capable of being determined in a s 81A referral.
3. There is significant authoritative support for this proposition; see particularly M v Allianz Australia Services Pty Ltd No. 2 [2019] TASWRCT 35.
4. With regard to the worker's assertions concerning the cogency of the evidence provided by the employer, I also accept the employer's submissions that the cases cited by the worker in support of the contention of evidentiary deficiencies in this case, being Alison Jane Connolly v P and O Resorts Pty Ltd t/as Cradle Mountain Lodge [1996] TASSC 132 and Lamont v MRD Supermarkets Pty Ltd [2016] TASSC 16, can be distinguished on the basis that the employer in this referral has provided the source information properly identifying it, and that no evidence in this case was attempted to be given from the bar table nor, in my view, in the written submissions of the employer.
5. I am satisfied that the evidence upon which the employer relies is well particularised with its source being identified.

1. For all of the reasons indicated above, I am satisfied that the employer has discharged its onus of proof to establish that there is a reasonably arguable case to dispute the worker's claim for compensation and that by virtue of s 81A(3)(c) and (d) weekly payments of compensation and the cost of benefits payable under Division 2 of Part VI of the WRC Act are not to be paid by the employer.

1. Pursuant to s 81A(3)(c) and (d) of the Workers Rehabilitation and Compensation Act 1988, compensation by way of weekly payments and the cost of benefits payable under Division 2 of Part VI of the Act are not to be paid by the employer to the worker.