Where a worker has suffered multiple distinct injuries at different times, the medical evidence must establish a causal connection between the specific compensable injury and the proposed treatment. The expenses of treatment directed at a condition arising from a non-compensable injury cannot be recovered as reasonable expenses under cl 17(1) of sch 1 of the Workers' Compensation and Injury Management Act 1981 (WA) merely because the worker had an earlier compensable injury to the same limb. Medical reports in workers' compensation proceedings must contain adequate explanation of medical terminology to enable a layperson tribunal to understand the evidence.
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