Insurance in MOtion April 2026

Welcome to Insurance in MOtion! We're excited to share the latest insights and updates with you.
May 4 2026

Duty of Care – Consent to Medical Procedures Informed by Hospital Policy

Gawthorp v Bendigo Health [2026] VSC 157

By Louise Cantrill, Partner, Tamara James. Associate and Lachlan Wong, Paralegal

A Victorian Supreme Court and Court of Appeal ruling has confirmed that medical procedures performed without genuine, voluntary consent, particularly where hospital policies undermine a patient’s stated wishes, can give rise to liability in both battery and negligence.

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A Bar Too High for Any Subpoena?  

Coker-Godson v Wangaratta Anglican Diocesan Corporations [2026] VSCA 72

By Stuart Eustice, Partner and Henry Van Til, Lawyer 

Warning: This article contains descriptions of sexual abuse. The content may be distressing or triggering for some readers. Please take care when reading and consider whether this material is appropriate for you at this time.

A recent Victorian Court of Appeal decision underscores the high statutory barrier to subpoenaing a sexual abuse complainant’s confidential counselling records, reinforcing the strength of legislative protections and the strict approach courts must take before compelling disclosure.

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Use the Gate! 

Woolnough v Whittelsea City Council & Anor [2026] VSC 190

By Stuart Eustice, Partner, William Gordon, Senior Associate and Henry Van Til, Lawyer

A serious spinal injury case highlights that councils may be liable for failing to address even low‑level safety risks where repeated use elevates danger, with contributory negligence reducing, but not defeating, a $19 million damages claim.

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Actual Knowledge Defeats Statutory Immunities: Council Liable for Concealed Verge Hazard

Orange City Council v Willis [2026] NSWCA 51

By Nikki Cassar, Partner and Lucas Oraha, Lawyer

The NSW Court of Appeal has confirmed that councils cannot rely on statutory immunity where they have actual knowledge, express or inferred, of a specific roadside hazard, particularly where the risk could have been addressed by simple, low‑cost measures.

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Not So Obvious: When Everyday Hazards Defeat the “Obvious Risks” Defence

The Owners – Strata Plan No 31337 v Balacco [2026] NSWCA 50

By Nikki Cassar, Partner and Lucas Oraha, Lawyer

The NSW Court of Appeal has clarified that occupiers cannot rely on the “obvious risk” defence where a commonplace hazard is not objectively obvious to all users, particularly where simple, low‑burden measures such as visual warnings could have reduced the risk of injury.

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