For the purposes of s 93D of the Workers' Compensation and Rehabilitation Act 1981 (WA), the 'degree of disability' looks to the overall condition of the worker, and disabilities from multiple distinct workplace injuries with one employer may be aggregated to meet the statutory threshold for access to common law damages. A medical report under s 93D(6) need not reference the statutory assessment criteria or expressly state that the disability is permanent, provided the report is not inconsistent with those requirements. However, Parker J's dissent on the permanence of psychiatric disability leaves some uncertainty about the adequacy of reports where the medical practitioner suggests the condition may resolve upon a future event.
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