In the recent case of Grant v Dateline Imports Pty Ltd
[2022] NSWPICPD 3, on appeal, Deputy President Wood confirmed the
worker must have evidence of a diagnosis in support of an alleged
consequential condition. The presence of symptoms, rather than a
diagnosis, was insufficient to support a finding of consequential
injury.
Facts
On 31 July 2015, the worker injured his right upper extremity at
work and the insurer accepted liability for the injury. The worker
subsequently alleged suffering consequential pain in his left upper
extremity as a result of overuse in favouring his injured right
arm, and a consequential complex regional pain syndrome (CRPS).
Several years later the worker claimed lump sum compensation
under section 66 of the Workers Compensation Act 1987 (the
1987 Act) for injury to both upper extremities and CRPS –
alleging consequential left upper extremity injury. The insurer
disputed liability for the alleged consequential condition of the
left
