Bilateral shoulder injuries sustained in a single accident cannot be aggregated as impairment of a single 'body function' under s 93(17)(a) of the Transport Accident Act 1986 (Vic). A 'body function' is a physical act or operation involving a part or closely connected parts of the body, distinguished from a higher-level activity combining multiple physical acts or operations. In assessing severity under para (c), the question of severity is bound up with causation, and a trial judge may have regard to treatment history and the extent to which medical evidence attributes the psychological condition to the accident.
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