A medical panel under the Accident Compensation Act 1985 (Vic) is not required to include members with specialist expertise sufficient to deal with every separate medical issue raised by the worker's condition; it may engage consultants and adopt their opinions as its own. The Wu Shan Liang caution against over-zealous judicial review applies with particular force to medical panels, which are non-adjudicative expert bodies. Where a panel states it has assessed impairment in accordance with the AMA Guides, there is a heavy onus on the challenger to demonstrate otherwise. Insistence on exact recitation of the language of the Guides at every point in the panel's reasons is the kind of over-zealous scrutiny prohibited on judicial review.
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