In serious injury applications under s.93(4)(d) of the Transport Accident Act 1986 involving aggravation of pre-existing conditions, the Petkovski v Galletti comparison test requires identification of the additional impairment attributable to the accident, but the majority held that a trial judge's reasons need not expressly name each opposing expert or rehearse their evidence in detail provided the reasons sufficiently identify the basis for preferring one body of evidence over another. The Court left open whether the Petkovski test adequately addresses cases where the accident tips a non-serious pre-existing impairment into serious territory for the first time. The adjective 'severe' in s.93(17)(c) imposes a stricter test than 'serious' in s.93(17)(a), and failure to apply the correct test is an error of law.
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