A Medical Assessment Panel's determination of permanent disability must be expressed as a specific percentage figure, not a percentage range, and must not be qualified by temporal limitations (such as covering only 2-5 years) that are inconsistent with the concept of permanence under Item 8 of Schedule 2 of the Workers' Compensation and Rehabilitation Act 1981 (WA). The MAP's reasons must, at a minimum, explain in general terms how and why it arrived at its conclusions against the background of conflicting medical evidence, though the standard expected is that of medical practitioners, not lawyers. The question whether inadequacy of reasons alone (as distinct from jurisdictional error) can ground certiorari against an inferior tribunal was left open by Murray J but accepted by the majority.
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