In this episode of P.I. Case Note, Michelle Wright examines the Queensland Industrial Relations Commission’s decision in Mastrangeli v Workers’ Compensation Regulator [2025] QIRC 263, which demonstrates the serious consequences of pursuing multiple claims for same workplace injury under different legislative regimes when the earlier claim has already been determined. The case involved Miss Mastrangeli, who alleged psychiatric injury from events on 4 December 2017 and 8 January 2018 while working for Queensland Police Service, and who pursued both anti-discrimination proceedings and workers’ compensation appeals based on the identical factual events—resulting in her compensation appeals being dismissed entirely after the discrimination claim failed.
The Commission’s comprehensive analysis reveals why pursuing multiple claims for same workplace injury can backfire under section 456 of the Industrial Relations Act 2016 (Qld), which permits dismissal when “the act or omission, the subject of the application or complaint is being or has been dealt with by the Commission in another proceeding.” Despite the claims falling under entirely different legislative regimes—the Anti-Discrimination Act and the Workers’ Compensation and Rehabilitation Act—the Commission found that both proceedings dealt with the same acts or omissions, namely the events on those two specific dates and allegations of desk tampering. Critically, the Commission had already heard evidence from the same witnesses, reached determinations about how those events should be categorised, and assessed the reasonableness of the parties’ conduct in the discrimination proceedings dismissed in October 2023. The Commission emphasised that the duplication consideration focuses on the factual act or omission regardless of the statutory relief sought, and that avoiding exploration of the same factual situations in multiple proceedings prevents ineffective use of public resources, provides finality in litigation, and avoids the scandal of conflicting decisions. Even if the Commission was wrong about some stressors predating December 2017, it would dismiss the appeals insofar as they related to the two key dates, and alternatively would dismiss under section 541 as not necessary or desirable in the public interest given the prejudice of requiring the same witnesses to testify about events over seven years old that they had already given evidence about three years earlier.
Listen for Michelle Wright’s detailed analysis of this important decision on multiple claims for same workplace injury and the strategic risks of overlapping litigation. If you’re considering pursuing workers’ compensation alongside discrimination or other claims arising from the same workplace events, the experienced team at accident legal understands the complex interaction between different legislative regimes. As Queensland’s trusted personal injury lawyers, we’ll develop a comprehensive legal strategy that maximises your remedies while avoiding the procedural traps of issue estoppel and res judicata that can result in losing all claims. Contact us for a free consultation on (07) 3740 0200—we’ll carefully coordinate your claims to ensure pursuing one avenue doesn’t jeopardise your rights under another.
