In this episode of P.I. Case Note, Michelle Wright examines the Queensland Industrial Relations Commission’s decision in Purse v Workers’ Compensation Regulator [2025] QIRC 299, which demonstrates how workplace bullying and psychiatric injury claims can succeed even when mixed with management action stressors. The case involved Mr Purse, employed by Toowoomba Regional Council, who alleged psychiatric injury from bullying and harassment by a colleague followed by council inaction, claimed 20 individual stressors in his statement of facts and contentions, but had his claim initially rejected by Local Government WorkCare and the Regulator—only to succeed on appeal when the Commission found that seven proven bullying incidents were the predominant cause of his injury despite some stressors being unsubstantiated and others involving reasonable management action.
The Commission’s comprehensive analysis reveals the proper approach to workplace bullying and psychiatric injury claims when multiple stressors of different types contribute to the injury. The Commission preferred Mr Purse’s evidence to his alleged bully Mr Williamson, finding Mr Williamson’s testimony “vague and self-serving” while Mr Purse’s evidence was “clear, direct” and included “appropriate concessions throughout.” Of the 20 alleged stressors, only nine were substantiated (three partially), with some not being stressors at all but rather symptom onset events, and others rejected based on Jones v Dunkel inferences when Mr Purse failed to call witnesses. Of the accepted stressors, seven related to bullying by Mr Williamson and two related to management action or inaction in response. Critically, the Commission emphasised that section 32(5) of the WCRA—which excludes injuries arising from reasonable management action taken in a reasonable way—concerns “only a slice of the employment” while section 32(1) covers “the whole gamut of the employment relationship.” The Commission stated the determination “is not by way of a mathematical exercise” but rather weighing reasonable management action against other employment factors. Finding that management action’s contribution to the injury was “minor” compared to the bullying stressors, and noting that initial medical records and claim documents referenced workplace bullying only as causative, the Commission concluded the injury arose predominantly from stressors relating to Mr Williamson rather than management action.
Listen for Michelle Wright’s detailed analysis of this important decision on workplace bullying and psychiatric injury claims and the critical distinction between bullying and management action. If you’re suffering from psychiatric injuries due to workplace bullying, the experienced team at accident legal understands how to prove workplace bullying and psychiatric injury claims even when some alleged stressors cannot be substantiated or involve management responses. As Queensland’s trusted personal injury lawyers, we know that section 32(5) doesn’t automatically defeat your claim when bullying is the predominant cause, and we’ll gather witness evidence to avoid adverse Jones v Dunkel inferences while building a case that demonstrates bullying’s significant contribution compared to any reasonable management action. Contact us for a free consultation on (07) 3740 0200. We’ll help you document all workplace stressors, identify which can be proven, and establish that bullying was the predominant cause of your psychiatric injury.
