Re Wong; Ex Parte Inghams Enterprises Pty Ltd

[2004] WASCA 247

Western Australia Court of Appeal

Built by Barristers,
For Australian Law.

See how it works

Interrogate

Catchwords

1. Administrative Law
2. › Prerogative writs
3. › Certiorari
4. › Adequacy of reasons
5. › Medical assessment panel
6. › Workers' compensation
7. › Whether panel provided adequate reasons where conclusions consistent with medical evidence
8. › Workers' Compensation and Rehabilitation Act 1981 (WA), s 145E
1. Workers' Compensation
2. › Medical assessment panel
3. › Referral under s 145E
4. › Adequacy of reasons for determination
5. › No universal formula
6. › Reasons assessed in light of circumstances of particular case
7. › Workers' Compensation and Rehabilitation Act 1981 (WA), s 145E

Quick Take

The adequacy of a medical assessment panel's reasons under s 145E of the Workers' Compensation and Rehabilitation Act 1981 (WA) is assessed contextually: where the panel's conclusions are consistent with the medical reports before it and there are no conflicting opinions to reconcile, brief or 'Spartan' reasons may be adequate. The guidelines in Re Croser; Ex parte Rutherford [2003] WASCA 8 are not a rigid formula.