(1) The Tribunal did apply the correct test of causation. Notwithstanding that the Tribunal, in its reasons, used the phrase "but for", nevertheless the Tribunal applied the test of predominant cause, and referred correctly to the relevant authorities.
(2) In respect of the first submission advanced on behalf of the appellant Mr Keogh made the following submissions:
(a) The appellant should not be permitted to make that submission. At the Tribunal the appellant did not, either in cross-examination or in final address, seek to contend that, if the brake had been left off and the gear engaged after the completion of repairs (as distinct from being in that condition after the vehicle was parked by Mr Billett), those two facts were features of the use, rather than of the driving, of the vehicle. At the Tribunal the Commission's submission was simply that Mr Billett was not driving the vehicle at the time of the accident, and that one hour had lapsed between the time when he last drove the vehicle and the happening of the accident.
(b) In any event, on the facts as found by it, the Tribunal did not err in finding that the incident was directly caused by the driving by Mr Billett of the vehicle.
The test of causation