In this revealing episode of P.I. Case Note, experienced personal injury lawyer Michelle Wright examines the Queensland Industrial Relations Commission’s decision in State of Queensland (Queensland Police Service) v Workers’ Compensation Regulator & Anor [2025] QIRC 203, which exposes the Queensland Police Service’s failure to meet its disclosure obligations in workers’ compensation proceedings. The case, decided by Commissioner Dwyer on 18 December 2025, involved Senior Constable Safi’s claim for Parkinson’s disease allegedly caused by prolonged mould exposure at Logan Central Police Station between 2009 and 2020, where the QPS’s inadequate disclosure practices led to a scathing judicial rebuke about model litigant principles.
The Commission’s detailed analysis under Rules 41(2)(o) and 46(1) of the Industrial Relations (Tribunal) Rules 2011 (Qld) and Rule 211 of the Uniform Civil Procedure Rules 1999 (Qld) demonstrates that disclosure obligations in workers’ compensation cases require parties to provide all directly relevant documents, not just those that support their position. Despite the QPS initially disclosing documents only from 2018-2023, Commissioner Dwyer found it “surprising” that no documents existed from 2010-2017, particularly when earlier documents referenced mould infestations dating back to at least 2011. The decision, which ordered disclosure of all mould-related documents from Mr. Safi’s entire employment period, reinforces that model litigants—especially government bodies—cannot delay proceedings or require opponents to prove matters they know to be true.
Listen for Michelle Wright’s comprehensive analysis of this important decision on disclosure obligations in workers’ compensation matters. Suppose you’re pursuing a work accident claim and facing resistance from employers or insurers in obtaining crucial documents. In that case, the experienced team at accident legal knows how to enforce proper disclosure and hold even government bodies accountable. With offices across Queensland from Brisbane to Cairns, our experienced workers’ compensation lawyers have successfully helped thousands of injured workers obtain the evidence needed to prove their claims. Contact us for a free consultation on (07) 3740 0200, we’ll ensure all relevant evidence comes to light to support your claim.
