Employers can avoid opening the floodgates on reasonable administrative action

While Lim certainly gives applicants a better grounding in bringing a claim, employers should not panic about the flood gates opening on old cases.

In 2005, Hart v Comcare [2005] FCAFC 16 set the causal standard for defending liability for workers' compensation claims under reasonable administrative action. Hart stands for the authority that, if an employee's injury has multiple causes, then only one of those causes needs to satisfy the exclusionary principle that an employee's injury was suffered "as a result of" reasonable disciplinary action.

This principle also extends to situations where the employee failed to obtain a promotion, transfer or benefit in connection with his or her employment. This principle is taken from section 5A(1) of the Safety, Rehabilitation and Compensation Act 1988 (Cth) (SRC Act).