A modified motor vehicle does not ordinarily constitute a 'medical, surgical or other similar aid or appliance' or a 'curative apparatus' within the definition of 'medical treatment' in s 4(1) of the Safety, Rehabilitation and Compensation Act 1988 (Cth). For a curative apparatus, the apparatus must be part of the process of treatment or the curative process, having as an essential characteristic its use in that process. Claims for vehicle acquisition and modification should be pursued under s 39(1)(d) or (e) rather than s 16. The Tribunal is not obliged to consider submissions filed without leave outside the scope of its directions, particularly where the claim was expressly disavowed at the hearing.
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