Psychological Injury at Work: A Look at Anderson v Workers’ Compensation Regulator

A recent Queensland Industrial Relations Commission (QIRC) decision has highlighted an important limit on psychological injury claims.

In Anderson v Workers’ Compensation Regulator [2025] QIRC 361, a nurse practitioner said she suffered a psychological injury after an upsetting interaction with a junior doctor. While her distress was real, the Commission ultimately found her injury was caused by reasonable management action taken in a reasonable way, and therefore not compensable under Queensland’s Workers’ Compensation and Rehabilitation Act 2003.

What Happened

The worker, an ENT nurse practitioner at Cairns Hospital, alleged that a junior doctor stormed into her clinic, accused her of missing a cancer diagnosis, and told her she was no longer allowed to see patients.

She said the exchange left her humiliated, fearful for her job, and unable to return to work.

But the doctor’s version of events was very different. He said the conversation was about reviewing a patient file together, giving clinical guidance, and letting her know that phone reviews were now to be handled by consultants and registrars, a departmental change already in place.

What the Commission Found

After hearing evidence from both sides, the Commission preferred the doctor’s evidence. It found that:

• The nurse’s account was inconsistent and not supported by the evidence.
• The interaction was short and professional, involving patient discussion and a management update.
• The doctor did not accuse her of missing a cancer diagnosis or bar her from seeing patients.

In other words, what occurred was reasonable management action, not bullying or misconduct.

The Legal Principle: Reasonable Management Action

Under Queensland law, a psychological or psychiatric injury is not compensable if it arises from:

• Reasonable management action,
• Taken in a reasonable way, or
• The worker’s perception of that action.

The QIRC reaffirmed that “reasonable” doesn’t mean “perfect”. Management actions can have flaws or be uncomfortable, what matters is whether they were fair, proportionate, and based on reason, not arbitrary or punitive.

Why the Claim Failed

The worker’s psychiatrist linked her condition to being accused of missing a cancer diagnosis and losing her role. But those facts weren’t proven. Because the medical opinion relied on a faulty factual foundation, it carried little weight.

Although the Commission accepted her employment contributed to her distress, it ruled that the injury was caused by reasonable management action, which excludes it from compensation under section 32(5) of the Workers’ Compensation and Rehabilitation Act 2003 (Qld).

The appeal was dismissed.

What This Means for Workers

This case shows how critical the evidence is in psychological injury claims.
Even where a worker genuinely suffers distress or illness, their claim may be rejected if the incident:

• Involved management doing its job reasonably; or
• Is based on a perception rather than what objectively occurred.

If you’ve suffered stress, anxiety, or depression related to work, it’s important to get early advice. A lawyer experienced in Queensland workers’ compensation law can help determine whether your situation meets the definition of a compensable injury — and protect your rights from the outset.

If you would like to discuss this decision further, or have questions, please contact us.