The Commission varied a notice of non-party disclosure served on a worker in a workers' compensation appeal, narrowing the scope of documents to be produced. The Commission confirmed that the 'train of inquiry' test from Peruvian Guano is no longer applicable to disclosure in the QIRC following the 2021 amendment inserting 'directly relevant' into r 46(1)(a), and that the same 'directly relevant' standard under r 64B(1)(a) applies to non-party disclosure. The Commission held that the timeframe for disclosure should be limited to the period ending at WorkCover's acceptance of the claim (not the later review decision date), that requests for communications about the WorkCover claim itself were either a fishing expedition or an impermissible attempt to obtain credibility-attack material, and that Document Category 4 (actions of the employer) must be confined to actions relied upon as causing or contributing to the injury.
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