What happened?

The worker had an accepted workplace psychological injury and later sought section 60 treatment for a consequential cervical condition (neck pain, muscular tension, posture-related symptoms, headaches). The respondent argued the neck history was tied to an earlier motor vehicle accident and prior damages settlement.

What the Commission decided

• The worker suffered a consequential cervical condition resulting from accepted psychological injury.
• A general section 60 order was made for treatment and related expenses.
• A specific $460 Botox item was ordered.
• Costs were awarded with 20% uplift for complexity.

Why this matters for workers

Insurers often frame these disputes as pre-existing pathology only. This case shows the Commission can still accept a consequential chain where psychological injury materially contributes to physical symptom expression and treatment need.

Section 151A argument in plain English

The respondent said prior motor vehicle damages blocked further compensation for neck-related issues. The Commission rejected that on these facts because it found a separate later causal domain from accepted workplace psychological injury.

Worker checklist if treatment is being denied

1. Get written denial reasons and preserve all notices/dates.
2. Build chronology showing symptom change after accepted work injury period.
3. Secure treating evidence on mechanism (tension, posture, pain amplification, function).
4. Map dispute route early instead of waiting until expenses escalate.

Decision source

Read the full decision: Jajaw v State of New South Wales (NSW Police Force) [2026] NSWPIC 166.