Background to the Decision
A recent decision of the Queensland Industrial Relations Commission (QIRC) has highlighted an important limit on claims for psychological injury arising from events at work.
In Anderson v Workers’ Compensation Regulator [2025] QIRC 361, a nurse practitioner alleged she suffered a psychological injury following an upsetting interaction with a junior doctor. Although the Commission accepted that she experienced distress, it ultimately found the condition arose from reasonable management action taken in a reasonable way. As a result, the injury was not compensable under the Workers’ Compensation and Rehabilitation Act 2003 (Qld).
What Happened
The worker was employed as an ENT nurse practitioner at Cairns Hospital. She claimed a junior doctor entered her clinic, accused her of failing to identify a cancer diagnosis in a patient, and told her she could no longer see patients.
According to the worker, the exchange left her feeling humiliated and fearful about the security of her role, and she said she was unable to return to work following the incident.
The doctor provided a different account. He stated that the discussion involved reviewing a patient file together, providing clinical guidance, and advising that phone-based patient reviews would now be handled by consultants and registrars as part of an existing departmental change.
Findings of the Commission
After hearing evidence from both parties, the Commission preferred the doctor’s version of events. It found:
- The nurse practitioner’s account contained inconsistencies and was not supported by other evidence.
- The interaction was brief and professional.
- The conversation involved discussing a patient and communicating a management change within the department.
- The doctor did not accuse the worker of missing a cancer diagnosis or prevent her from seeing patients.
On that basis, the Commission concluded the interaction amounted to reasonable management action rather than bullying or misconduct.
The Legal Principle: Reasonable Management Action
Under Queensland workers’ compensation legislation, a psychological or psychiatric injury is not compensable if it arises from reasonable management action taken in a reasonable way.
This exclusion can apply where the injury results from:
- Management decisions or directions;
- Performance discussions or feedback; or
- A worker’s perception of management conduct.
The Commission reiterated that “reasonable” does not require management conduct to be perfect. An action may still be considered reasonable even if it is uncomfortable or involves criticism, provided it is proportionate, fair in the circumstances, and not arbitrary or punitive.
Why the Claim Was Unsuccessful
The worker’s psychiatrist attributed her psychological condition to being accused of missing a cancer diagnosis and effectively losing her clinical role. However, the Commission found those events had not occurred.
Because the medical opinion relied on facts that were not established by the evidence, it was given limited weight. While the Commission accepted the worker had experienced distress connected with her employment, it concluded the condition arose from reasonable management action.
Section 32(5) of the Workers’ Compensation and Rehabilitation Act 2003 (Qld) excludes such circumstances from compensation. The worker’s appeal was therefore dismissed.
What This Means for Workers
The decision illustrates the importance of evidence in psychological injury claims.
Even where a worker genuinely experiences stress, anxiety, or another psychological condition, a claim may fail if the injury results from management performing its role in a reasonable manner or if the claim relies on a perception of events that is not supported by the evidence.
Workers who believe their mental health has been affected by events at work may benefit from obtaining early legal advice to better understand whether their circumstances fall within the definition of a compensable injury under Queensland law.
