Chapter 9. WORKERS' COMPENSATION  

CROSS REFERENCES. --Compensation of employees of state institutions who contract tuberculosis or infectious hepatitis, Ch. 29, T. 31. Liability of employers for injuries to employees generally, § 34-7-20 et seq. Additional payments to members of Georgia State Patrol for injuries received in line of duty, § 35-2-9. Additional payments to members of Georgia Bureau of Investigation for injuries received in line of duty, § 35-3-12. Indemnification of law enforcement officers, firefighters, and prison guards for death or disablement in line of duty, § 45-9-80 et seq. Public assistance, Ch. 4, T. 49.
 
EDITOR'S NOTES. --Code Sections 34-9-18, 34-9-82, 34-9-100, 34-9-102, 34-9-104, 34-9-108, 34-9-201, 34-9-205, 34-9-221, 34-9-222, 34-9-241, 34-9-243, and 34-9-261 through 34-9-263 were amended by Ga. L. 1978, p. 2220. The provisions of Code Sections 34-9-261 through 34-9-263, and any other provision of the amendment which created a substantive right, shall apply to any accident or injury occurring on or after July 1, 1978. In all other respects, including all procedural matters, the provisions shall apply to any action taken on or after July 1, 1978, without regard to the date of accident or injury.
 
ADMINISTRATIVE RULES AND REGULATIONS. --Workers' compensation insurance statistical agent, Official Compilation of the Rules and Regulations of the State of Georgia, Office of Commissioner of Insurance, Chapter 120-2-36.
   Georgia workers' compensation insurance rate filings, Official Compilation of the Rules and Regulations of the State of Georgia, Office of Commissioner of Insurance, Chapter 120-2-37.
   Georgia workers compensation assigned risk insurance plan, Official Compilation of the Rules and Regulations of the State of Georgia, Office of Commissioner of Insurance, Chapter 120-2-38.
 
LAW REVIEWS. --For article surveying history of workers' compensation laws and their application in this state, see 11 Ga. B.J. 413 (1949). For article, "Quasi-Municipal Tort Liability in Georgia," see 6 Mercer L. Rev. 287 (1955). For article, "1955 Amendments to the Georgia Workmen's Compensation Law," see 18 Ga. B.J. 307 (1956). For article, "Actions for Wrongful Death in Georgia: Part One," see 19 Ga. B.J. 277 (1957). For article, "Actions for Wrongful Death in Georgia: Part Two," see 19 Ga. B.J. 439 (1957). For article, "Actions for Wrongful Death in Georgia: Parts Three and Four," see 21 Ga. B.J. 339 (1959). For article arguing for inclusion of the State Board of Workers' Compensation under the Georgia Administrative Procedure Act (Ch. 13, T. 50), see 1 Ga. St. B.J. 269 (1965). For article, "Conflict of Laws in Damage Suits Related to Workmen's Compensation Cases," see 28 Mercer L. Rev. 497 (1977). For article surveying Georgia cases dealing with workers' compensation from June 1, 1976 through May 31, 1978, see 30 Mercer L. Rev. 269 (1978). For article, "Psychological Injury in Workers' Compensation," see 16 Ga. St. B.J. 18 (1979). For article surveying recent legislative and judicial developments regarding Georgia's insurance laws, see 31 Mercer L. Rev. 117 (1979). For article, "Workers' Compensation in Georgia Municipal Law," see 15 Ga. L. Rev. 57 (1980). For article surveying Georgia cases in the area of workers' compensation from June 1979 through May 1980, see 32 Mercer L. Rev. 261 (1980). For survey article on workers' compensation, see 34 Mercer L. Rev. 335 (1982). For annual survey of workers' compensation law, see 35 Mercer L. Rev. 359 (1983). For annual survey of workers' compensation law, see 36 Mercer L. Rev. 393 (1984). For article surveying workers' compensation law in 1984-1985, see 37 Mercer L. Rev. 461 (1985). For annual survey of workers' compensation law, see 39 Mercer L. Rev. 377 (1987). For article, "On Reintegrating Workers' Compensation and Employers' Liability," see 21 Ga. L. Rev. 843 (1987). For annual survey of law of workers' compensation, see 40 Mercer L. Rev. 487 (1988). For article, "Change in Condition v. New Accident: Old Problems Revisited," see 40 Mercer L. Rev. 961 (1989). For annual survey of workers' compensation law, see 41 Mercer L. Rev. 429 (1989). For annual survey of workers' compensation law, see 42 Mercer L. Rev. 505 (1990). For article, "The Status of the Workers' Compensation System in Georgia and Proposed Changes: Remedies for the Remedy," see 7 Ga. St. U.L. Rev. 25 (1990). For annual survey of workers' compensation law, see 43 Mercer L. Rev. 475 (1991). For annual survey of workers' compensation law, see 44 Mercer L. Rev. 457 (1992). For annual survey article on workers' compensation law, see 45 Mercer L. Rev. 493 (1993). For annual survey article on workers' compensation law, see 50 Mercer L. Rev. 401 (1998). For annual survey article discussing workers' compensation law, see 52 Mercer L. Rev. 505 (2000). For article, "Report of the Governor's Workers' Compensation Review Commission," see 38 Ga. L. Rev. 1241 (2004). For article, "Pandemic Preparation in the Workplace," see 12 Ga. St. B.J. 14 (2006).
   For note, "The Worker's Compensation Insurer as a Third Party Tortfeasor in Georgia," see 30 Mercer L. Rev. 339 (1978). For note discussing compensation under this title for original injuries aggravated by subsequent injury, continued employment, or ordinary activity, see 31 Mercer L. Rev. 325 (1979).
   For comment on Ladson Motor Co. v. Croft, 212 Ga. 275, 92 S.E.2d 103 (1956), see 19 Ga. B.J. 237 (1956).
 
JUDICIAL DECISIONS
 
CONSTITUTIONALITY OF THIS CHAPTER. --As to the constitutionality of the workers' compensation law, see Metropolitan Cas. Ins. Co. v. Huhn, 165 Ga. 667, 142 S.E. 121, 59 A.L.R. 719 (1928); City of Macon v. Benson, 175 Ga. 502, 166 S.E. 26 (1932); Garner v. Owens-Illinois Glass Container, 134 Ga. App. 917, 216 S.E.2d 709 (1975).
 
INTENT TO BROADEN COVERAGE OF CHAPTER. --Recent history of this state's workers' compensation laws, especially former Code 1933, §§ 114-101 and 114-102 (see O.C.G.A. § 34-9-1), evidences an unmistakable legislative intent to broaden the coverage of the workers' compensation law by expanding the scope of the word "employer." Gaither v. Fulton-DeKalb Hosp. Auth., 144 Ga. App. 16, 240 S.E.2d 560 (1977), rev'd on other grounds, 241 Ga. 572, 247 S.E.2d 89 (1978).
 
PUBLIC INTEREST IN INDUSTRIAL ACCIDENTS. --The fundamental basis of workers' compensation laws is that there is a large element of public interest in accidents occurring from modern industrial conditions, and that the economic loss caused by such accidents should not necessarily rest upon the public, but that the industry in which an accident occurred shall pay, in the first instance, for the accident. Globe Indem. Co. v. Lankford, 35 Ga. App. 599, 134 S.E. 357 (1926).
 
NATURE OF EMPLOYER'S LIABILITY. --An employer is liable under the workers' compensation law without regard to fault or negligence. Gay v. Greene, 91 Ga. App. 78, 84 S.E.2d 847 (1954).
 
BURDEN OF PROOF. --The obligation of an employer under the workers' compensation law is not that of an absolute insurer, and hence the burden is on the claimant to prove a case to which the law is applicable. Ladson Motor Co. v. Croft, 212 Ga. 275, 92 S.E.2d 103 (1956), for comment, see 19 Ga. B.J. 237 (1956).
 
UNEMPLOYMENT BENEFITS. --The receipt of unemployment benefits does not estop a claimant from receiving compensation benefits under the workers' compensation law. James v. GMC, 107 Ga. App. 588, 131 S.E.2d 58 (1963).
 
CODE OF LAWS. --Ordinary rules of law do not apply to actions arising under the workers' compensation law (see O.C.G.A. § 34-9-1 et seq.), as the law itself constitutes a complete code of laws upon the subject. Tillman v. Moody, 181 Ga. 530, 182 S.E. 906 (1935).
   The workers' compensation law (see O.C.G.A. § 34-9-1 et seq.) embodies within itself a complete code of laws upon the subject, and is complete within itself as to its own subject matter. Zachery v. Royal Indem. Co., 80 Ga. App. 659, 56 S.E.2d 812 (1949), overruled on other grounds, Freeman Decorating Co. v. Subsequent Injury Trust Fund, 175 Ga. App. 369, 333 S.E.2d 204 (1985).
   The workers' compensation law (see O.C.G.A. § 34-9-1 et seq.) constitutes a complete code of laws upon the subject of the rights and remedies of employers, employees, and their dependents, and the Court of Appeals can neither rewrite this title nor hedge it about with restrictions not included in it. St. Paul Fire & Marine Ins. Co. v. Miniweather, 119 Ga. App. 617, 168 S.E.2d 341 (1969).
   The workers' compensation law (see O.C.G.A. § 34-9-1 et seq.) constitutes a complete code of laws upon its administration, and no contract or agreement, whether written, oral, or implied, can in any manner operate to change the law. Fireman's Fund Ins. Co. v. Crowder, 123 Ga. App. 469, 181 S.E.2d 530 (1971).
 
APPLICABILITY OF ABUSIVE LITIGATION STATUTE. --The abusive litigation statute (O.C.G.A. § 51-7-80 et seq.) does not authorize a claim for abusive litigation in the context of the Workers' Compensation Act, O.C.G.A. Ch. 9, T. 34. Patterson v. Cox Enters., Inc., 201 Ga. App. 222, 411 S.E.2d 85 (1991).
 
MISREPRESENTATION OF THE EMPLOYEE'S PHYSICAL CONDITION IN AN EMPLOYMENT APPLICATION will bar workers' compensation benefits if: (1) the employee has knowingly and wilfully made a false representation as to the employee's physical condition; (2) the employer has relied upon the false representation and such reliance was a substantial factor in the hiring; and (3) there was a causal connection between the false representation and the injury. Georgia Elec. Co. v. Rycroft, 259 Ga. 155, 378 S.E.2d 111 (1989).
   A representation made during an employment intake process, but before the employee begins actual work, may constitute a "substantial factor in the hiring" within the meaning of Georgia Elec. Co. v. Rycroft, 259 Ga. 155, 378 S.E.2d 111 (1989). Fort Howard Corp. v. Devoe, 212 Ga. App. 602, 442 S.E.2d 474 (1994).
 
FALSE REPRESENTATION DEFENSE. --The decision in Georgia Elec. Co. v. Rycroft, 259 Ga. 155, 378 S.E.2d 111 (1989), adopting the false representation defense, is not inconsistent with provisions of the Americans with Disabilities Act, title 42 of the United States Code. Caldwell v. Aarlin/Holcombe Armature Co., 267 Ga. 613, 481 S.E.2d 196 (1997).
 
MISREPRESENTATIONS OF AN EMPLOYEE'S RESIDENT STATUS did not bar the employee from entitlement to workers' compensation benefits where there was no showing of a causal connection between the misrepresentation and the injury the employee suffered. Dynasty Sample Co. v. Beltran, 224 Ga. App. 90, 479 S.E.2d 773 (1996).
 
ENFORCEABILITY OF OUT-OF-STATE POLICY. --In the case of a workers' compensation policy which was executed in Tennessee, a clear limitation in the policy to Tennessee benefits did not violate public policy and was enforceable in Georgia. Travelers Ins. Co. v. McNabb, 201 Ga. App. 297, 410 S.E.2d 788, cert. denied, 201 Ga. App. 904, 410 S.E.2d 788 (1991), overruled on other grounds, Yoho v. Ringier of Am., Inc., 263 Ga. 338, 434 S.E.2d 57 (1993).
 
SEXUAL HARASSMENT. --A female employee's common-law tort claim of assault against her supervisor and their employer is not barred by the workers' compensation law (see O.C.G.A. § 34-9-1 et seq.), where the supervisor's alleged acts were not in furtherance of the employer's business but independent of the relation of master and servant and the theory of recovery against the employer sounds in common-law tort, i.e., the employer's negligence in allowing the supervisor to remain in a supervisory position with notice of the supervisor's proclivity to engage in sexually offensive conduct directed against female employees. Cox v. Brazo, 165 Ga. App. 888, 303 S.E.2d 71, aff'd, 251 Ga. 491, 307 S.E.2d 474 (1983).
 
INJURIES IN NAVIGABLE WATERS. --A fatal injury which occurred while the deceased was strictly engaged in the deceased's duty as a fisherman in navigable waters fell under maritime law and was within the exclusive jurisdiction of the federal courts. Maryland Cas. Co. v. Grant, 169 Ga. 325, 150 S.E. 424 (1929), appeal dismissed, 281 U.S. 690, 50 S. Ct. 240, 74 L. Ed. 1120 (1930).
   Where the claimant was employed to go out in a boat into navigable waters and catch fish, and while in a navigable stream, after getting the boat back into it after it had become stuck in mud, the claimant was injured by the claimant's coat being caught in the windlass and the claimant's arm pulled into the machine, the matter was one involving exclusive admiralty and maritime jurisdiction, and the injury was therefore not compensable under the workers' compensation law (see O.C.G.A. § 34-9-1 et seq.). Saleens v. Travelers' Ins. Co., 47 Ga. App. 532, 171 S.E. 159 (1933).
   The workers' compensation law (see O.C.G.A. § 34-9-1 et seq.), rather than general maritime law, applied in the case of a land-based electrician's suit against an employer for injuries sustained in a boating accident which occurred within state waters while the electrician was being transported to the work site. Brockington v. Certified Elec., Inc., 903 F.2d 1523 (11th Cir. 1990), cert. denied, 498 U.S. 1026, 111 S. Ct. 676, 112 L. Ed. 2d 668 (1991).
   Concurrent jurisdiction exists under the Longshoremen's & Harbor Workers' Compensation Act, 33 U.S.C. § 901 et seq., and the Georgia Workers' Compensation Act, O.C.G.A. § 34-9-1 et seq., for injuries sustained by a stevedore on navigable waters. Allsouth Stevedoring Co. v. Wilson, 220 Ga. App. 205, 469 S.E.2d 348 (1996).
 
EFFECT OF STATUTORY AMENDMENTS. --As to the effect of amendments to the Workmen's Compensation Act, O.C.G.A. § 34-9-1 et seq., on existing and terminated employment relationships, see Venable v. John P. King Mfg. Co., 174 Ga. App. 800, 331 S.E.2d 638 (1985).
 
CITED in Fulton Bakery, Inc. v. Williams, 35 Ga. App. 681, 134 S.E. 621 (1926); McCoy v. Southern Lumber Co., 38 Ga. App. 251, 143 S.E. 611 (1928); United States Cas. Co. v. Burton-Pitt Lumber Co., 41 Ga. App. 405, 152 S.E. 919 (1930); Donaldson v. Central of Ga. Ry., 43 Ga. App. 480, 159 S.E. 738 (1931); Threatt v. American Mut. Liab. Ins. Co., 173 Ga. 350, 160 S.E. 379 (1931); Smith v. John T. Ragan & Co., 44 Ga. App. 111, 160 S.E. 538 (1931); Murphy v. Constitution Indem. Co., 174 Ga. 243, 162 S.E. 629 (1932); Smith v. Standard Oil Co., 178 Ga. 651, 173 S.E. 379 (1934); Bentley v. Jones, 48 Ga. App. 587, 173 S.E. 737 (1934); Swift & Co. v. Alston, 48 Ga. App. 649, 173 S.E. 741 (1934); DeKalb County v. Grice, 179 Ga. 458, 175 S.E. 804 (1934); Zurich Gen. Accident & Liab. Co. v. Stein & Co., 50 Ga. App. 503, 179 S.E. 142 (1935); Ocean Accident & Guarantee Corp. v. Farr, 51 Ga. App. 147, 179 S.E. 841 (1935); Travelers Ins. Co. v. Reid, 54 Ga. App. 13, 186 S.E. 887 (1936); Hunter v. Employers Liab. Assurance Corp., 54 Ga. App. 197, 187 S.E. 209 (1936); Martin v. State Hwy. Bd., 54 Ga. App. 856, 189 S.E. 614 (1936); Travelers Ins. Co. v. Anderson, 185 Ga. 105, 194 S.E. 193 (1937); American Sur. Co. v. Castleberry, 57 Ga. App. 402, 195 S.E. 590 (1938); Ingram v. Parrish, 58 Ga. App. 463, 198 S.E. 842 (1938); Adams v. Glens Falls Indem. Co., 58 Ga. App. 663, 199 S.E. 783 (1938); U.S. Fid. & Guar. Co. v. Neal, 60 Ga. App. 179, 3 S.E.2d 211 (1939); American Mut. Liab. Ins. Co. v. Sims, 62 Ga. App. 424, 8 S.E.2d 408 (1940); Hartford Accident & Indem. Co. v. Cox, 63 Ga. App. 763, 12 S.E.2d 110 (1940); Ocean Accident & Guarantee Corp. v. Lane, 64 Ga. App. 149, 12 S.E.2d 413 (1940); Bituminous Cas. Corp. v. Wilbanks, 64 Ga. App. 232, 12 S.E.2d 479 (1940); Richie & Co. v. Cohen, 65 Ga. App. 30, 14 S.E.2d 603 (1941); Travelers Ins. Co. v. Lester, 73 Ga. App. 465, 36 S.E.2d 880 (1946); Beasley v. Burt, 201 Ga. 144, 39 S.E.2d 51 (1946); Bituminous Cas. Corp. v. Southwell, 78 Ga. App. 609, 51 S.E.2d 729 (1949); Holtzendorf v. Glynn, 79 Ga. App. 44, 52 S.E.2d 671 (1949); Free v. McEver, 79 Ga. App. 831, 54 S.E.2d 372 (1949); Maryland Cas. Co. v. Mitchell, 82 Ga. App. 439, 61 S.E.2d 506 (1950); Mayo v. McClung, 83 Ga. App. 548, 64 S.E.2d 330 (1951); Massachusetts Bonding & Ins. Co. v. Turk, 84 Ga. App. 547, 66 S.E.2d 364 (1951); Miller v. Independent Life & Accident Ins. Co., 86 Ga. App. 538, 71 S.E.2d 705 (1952); Fidelity & Cas. Co. v. Landers, 89 Ga. App. 100, 78 S.E.2d 878 (1953); Smith v. Globe Indem. Co., 89 Ga. App. 498, 80 S.E.2d 57 (1954); Combs v. Carolina Cas. Ins. Co., 90 Ga. App. 90, 82 S.E.2d 32 (1954); Taylor v. Smith, 211 Ga. 5, 83 S.E.2d 602 (1954); Great Am. Indem. Co. v. Overton, 92 Ga. App. 238, 88 S.E.2d 498 (1955); Creech v. Sirkin, 92 Ga. App. 509, 88 S.E.2d 697 (1955); Johnson v. United States Fid. & Guar. Co., 93 Ga. App. 336, 91 S.E.2d 779 (1956); Board of Rd. & Revenue Comm'r v. Collins, 94 Ga. App. 562, 95 S.E.2d 758 (1956); DeKalb County v. Brown, 97 Ga. App. 572, 103 S.E.2d 600 (1958); Morgan County v. Craig, 97 Ga. App. 571, 103 S.E.2d 756 (1958); West End Cab Co. v. Stovall, 98 Ga. App. 724, 106 S.E.2d 810 (1958); United States Fid. & Guar. Co. v. Giddens, 102 Ga. App. 576, 116 S.E.2d 883 (1960); Hopkins v. Employers Mut. Liab. Ins. Co., 103 Ga. App. 579, 120 S.E.2d 321 (1961); Ocean Accident & Guarantee Corp. v. Bates, 104 Ga. App. 621, 122 S.E.2d 305 (1961); Alexander v. Globe Indem. Co., 105 Ga. App. 212, 124 S.E.2d 428 (1962); Georgia Power Co. v. Carter, 110 Ga. App. 233, 138 S.E.2d 182 (1964); Carpenter v. Newcomb Devilbiss Co., 111 Ga. App. 472, 142 S.E.2d 381 (1965); Pittsburgh Plate Glass Co. v. Bailey, 111 Ga. App. 609, 142 S.E.2d 388 (1965); Argonaut Ins. Co. v. Wilson, 119 Ga. App. 121, 166 S.E.2d 641 (1969); State Farm Mut. Auto. Ins. Co. v. Board of Regents of Univ. Sys., 226 Ga. 310, 174 S.E.2d 920 (1970); Mull v. Aetna Cas. & Sur. Co., 226 Ga. 462, 175 S.E.2d 552 (1970); Department of Transp. v. Livaditis, 129 Ga. App. 358, 199 S.E.2d 573 (1973); Fox v. Hartford Accident & Indem. Co., 130 Ga. App. 104, 202 S.E.2d 568 (1973); Woods v. Piggly Wiggly S., Inc., 133 Ga. App. 719, 213 S.E.2d 22 (1975); Employers Ins. v. Nolen, 137 Ga. App. 205, 223 S.E.2d 250 (1976); Moone v. Liberty Mut. Ins. Co., 145 Ga. App. 629, 244 S.E.2d 148 (1978); Bituminous Cas. Corp. v. Ashbaugh, 147 Ga. App. 392, 249 S.E.2d 96 (1978); University Cab, Inc. v. Fagan, 150 Ga. App. 404, 258 S.E.2d 21 (1979); Samuel v. Baitcher, 154 Ga. App. 602, 269 S.E.2d 96 (1980); Mansfield Enters., Inc. v. Warren, 154 Ga. App. 863, 270 S.E.2d 72 (1980); Helton v. Interstate Brands Corp., 155 Ga. App. 607, 271 S.E.2d 739 (1980); Spencer v. Moore Bus. Forms, Inc., 87 F.R.D. 118 (N.D. Ga. 1980); Lowe v. Chemical Sealing Corp., 535 F. Supp. 1280 (N.D. Ga. 1982); Atkins v. Tri-Cities Steel, Inc., 166 Ga. App. 349, 304 S.E.2d 409 (1983); Mattison v. Travelers Indem. Co., 167 Ga. App. 521, 307 S.E.2d 39 (1983); General Am. Life Ins. Co. v. Barth, 167 Ga. App. 605, 307 S.E.2d 113 (1983); Southern Fried Chicken v. Thermo-King Corp., 172 Ga. App. 454, 323 S.E.2d 291 (1984); Jackson v. Southern Bell Tel. & Tel. Co., 178 Ga. App. 673, 344 S.E.2d 495 (1986).
 
LIBERAL CONSTRUCTION. --Although the workers' compensation law (see O.C.G.A. § 34-9-1 et seq.) is in derogation of the common law, due to its beneficent purposes it should, when construction is necessary, be given a liberal construction. Brown v. Lumbermen's Mut. Cas. Co., 49 Ga. App. 99, 174 S.E. 359 (1934).
   Liberal construction must be given to the workers' compensation law (see O.C.G.A. § 34-9-1 et seq.) to effectuate the humane purposes for which it was enacted. Davis v. Bibb Mfg. Co., 75 Ga. App. 515, 43 S.E.2d 780 (1947); Coulter v. Royal Indem. Co., 95 Ga. App. 124, 97 S.E.2d 358, rev'd on other grounds, 213 Ga. 277, 98 S.E.2d 899 (1957); Schwartz v. Greenbaum, 236 Ga. 476, 224 S.E.2d 38 (1976).
   The workers' compensation law (see O.C.G.A. § 34-9-1 et seq.) should be liberally construed. Fidelity & Cas. Co. v. Windham, 87 Ga. App. 198, 73 S.E.2d 517 (1952), rev'd on other grounds, 209 Ga. 592, 74 S.E.2d 835 (1953); Hartford Accident & Indem. Co. v. Souther, 110 Ga. App. 84, 137 S.E.2d 705 (1964); Insurance Co. of N. Am. v. Cooley, 118 Ga. App. 46, 162 S.E.2d 821 (1968).
 
ORDINARY ACCEPTANCE OF CHAPTER'S TERMS. --Where its language is such as to render judicial construction necessary, nevertheless a reasonable and logical application of the workers' compensation law (see O.C.G.A. § 34-9-1 et seq.) should be had according to the ordinary acceptance and significance of its terms. Harden v. United States Cas. Co., 49 Ga. App. 340, 175 S.E. 404 (1934).
   A reasonable and logical application of the workers' compensation law (see O.C.G.A. § 34-9-1 et seq.) should be had according to the ordinary and usual acceptance and significance of its terms. Wilson v. Maryland Cas. Co., 71 Ga. App. 184, 30 S.E.2d 420 (1944).
 
PREVENTION OF MISCARRIAGE OF COMPENSATION PURPOSES. --A compensation act will be reasonably construed so as to prevent, if possible, miscarriage of the objects and benefits for which it is designed. United States Fid. & Guar. Co. v. Maddox, 52 Ga. App. 416, 183 S.E. 570 (1935).
 
INTERPRETATION IN FAVOR OF CLAIMANTS. --In order to accomplish its beneficent purposes, the workers' compensation law (see O.C.G.A. § 34-9-1 et seq.) is to be interpreted liberally in favor of those claiming compensation. GMC, Fisher Body Div. v. Bowman, 107 Ga. App. 335, 130 S.E.2d 163 (1963); GMC v. Hargis, 114 Ga. App. 143, 150 S.E.2d 303 (1966).
 
NECESSARY MEANING OF TERMS. --While the workers' compensation law (see O.C.G.A. § 34-9-1 et seq.) is to be given a liberal construction when necessary to effectuate its beneficent purposes, this rule does not authorize a construction beyond what appears to be the necessary meaning of its terms. United States Fid. & Guar. Co. v. Neal, 188 Ga. 105, 3 S.E.2d 80 (1939).
 
INTENT OF LEGISLATURE. --The liberal construction of the workers' compensation law (see O.C.G.A. § 34-9-1 et seq.) can only be had where judicial interpretation is necessary, and the law should not be so liberally construed as to defeat the purposes and intents of the legislation. Southern Cotton Oil Co. v. McLain, 49 Ga. App. 177, 174 S.E. 726 (1934).
   The workers' compensation law (see O.C.G.A. § 34-9-1 et seq.) should be liberally construed so as to effect the purposes intended by the legislature in its enactment. Ware v. Swift & Co., 59 Ga. App. 836, 2 S.E.2d 128 (1939); Bethlehem Steel Co. v. Dempsey, 94 Ga. App. 408, 94 S.E.2d 749 (1956).
 
REMEDIAL PURPOSES. --The workers' compensation law (see O.C.G.A. § 34-9-1 et seq.) is a remedial statute and must be given a liberal construction. Southern Cotton Oil Co. v. McLain, 49 Ga. App. 177, 174 S.E. 726 (1934).
   The workers' compensation law (see O.C.G.A. § 34-9-1 et seq.) is remedial and has a beneficent purpose, and it should be accorded a liberal and broad construction or interpretation in order to promote or effectuate its purposes. Continental Cas. Co. v. Haynie, 51 Ga. App. 650, 181 S.E. 126 (1935), aff'd, 182 Ga. 608, 186 S.E. 683 (1936).
   The workers' compensation law (see O.C.G.A. § 34-9-1 et seq.) is to be interpreted liberally to effectuate its remedial purposes. Travelers Ins. Co. v. Gaither, 148 Ga. App. 251, 251 S.E.2d 66 (1978).
   The workers' compensation law (see O.C.G.A. § 34-9-1 et seq.), although in derogation of the common law, is highly remedial in character and should be liberally and broadly construed to effect its beneficent purposes. London Guarantee & Accident Co. v. Cox, 41 Ga. App. 329, 153 S.E. 227 (1930); Harden v. United States Cas. Co., 49 Ga. App. 340, 175 S.E. 404 (1934); Western Union Tel. Co. v. Smith, 50 Ga. App. 585, 178 S.E. 472 (1935); United States Fid. & Guar. Co. v. Maddox, 52 Ga. App. 416, 183 S.E. 570 (1935); Glens Falls Indem. Co. v. Sockwell, 58 Ga. App. 111, 197 S.E. 647 (1938); Wilson v. Maryland Cas. Co., 71 Ga. App. 184, 30 S.E.2d 420 (1944); Zachery v. Royal Indem. Co., 80 Ga. App. 659, 56 S.E.2d 812 (1949); Coulter v. Royal Indem. Co., 95 Ga. App. 124, 97 S.E.2d 358, rev'd on other grounds, 213 Ga. 277, 98 S.E.2d 899 (1957); McElreath v. McElreath, 155 Ga. App. 826, 273 S.E.2d 205 (1980).
 
HUMANITARIAN PURPOSE. --The workers' compensation law (see O.C.G.A. § 34-9-1 et seq.) is a humanitarian measure providing relief to injured employees and protecting employers from excessive damage awards, and should be liberally interpreted to carry out this purpose. Samuel v. Baitcher, 247 Ga. 71, 274 S.E.2d 327 (1981).
 
BENEFICENT PURPOSES. --While the workers' compensation law (see O.C.G.A. § 34-9-1 et seq.) is in derogation of the common law, yet, in view of its beneficent purpose and remedial character, it should be so liberally and broadly construed as to effect its general purpose in every instance in which its language is such as to render judicial interpretation necessary. New Amsterdam Cas. Co. v. Sumrell, 30 Ga. App. 682, 118 S.E. 786 (1923); Van Treeck v. Travelers Ins. Co., 157 Ga. 204, 121 S.E. 215 (1924); Austin Bros. Bridge Co. v. Whitmire, 31 Ga. App. 560, 121 S.E. 345 (1924).
   The workers' compensation law (see O.C.G.A. § 34-9-1 et seq.) is to be construed reasonably and liberally, with a view of applying its beneficent provisions so as to effectuate its purposes, and to extend them to every class of workman and employee that can fairly be brought within its provisions. Gaither v. Fulton-DeKalb Hosp. Auth., 144 Ga. App. 16, 240 S.E.2d 560 (1977), rev'd on other grounds, 241 Ga. 572, 247 S.E.2d 89 (1978); Gulf Am. Fire & Cas. Co. v. Taylor, 150 Ga. App. 179, 257 S.E.2d 44 (1979).
   
 
PUBLIC DEMAND. --The workers' compensation law (see O.C.G.A. § 34-9-1 et seq.) arose from public demand and attempts to solve certain pressing problems which have arisen out of the changed industrial conditions of our time. Brown v. Lumbermen's Mut. Cas. Co., 49 Ga. App. 99, 174 S.E. 359 (1934).
 
PROTECTION FROM ECONOMIC HAZARDS. --The workers' compensation law (see O.C.G.A. § 34-9-1 et seq.) was enacted to protect the worker in some measure from economic hazards consequent upon the worker's exposure to today's manifold industrial hazards to life and health. Utica Mut. Ins. Co. v. Pioda, 90 Ga. App. 593, 83 S.E.2d 627 (1954).
 
INSURANCE AGAINST PERSONAL INJURIES. --The purpose of the workers' compensation law (see O.C.G.A. § 34-9-1 et seq.) is to insure the workman against personal injuries not expected or designed by the workman personally, provided such injury arises out of and in the course of employment. Scott v. Travelers' Ins. Co., 49 Ga. App. 157, 174 S.E. 629 (1934).
 
INJURIES RESULTING FROM EMPLOYER'S NEGLIGENCE. --The workers' compensation law (see O.C.G.A. § 34-9-1 et seq.) was intended to include injuries resulting from the negligence of the employer in every particular, whether arising under common law or statutory duties, and the pain and suffering incident to such injuries. Reid v. Lummus Cotton Gin Co., 58 Ga. App. 184, 197 S.E. 904 (1938).
 
PROTECTION FROM WANT. --The workers' compensation law (see O.C.G.A. § 34-9-1 et seq.) was adopted to protect working individuals and their dependents from want in case of injury, on the theory that contributory negligence, the doctrine of fellow servant negligence, and assumption of risk are inapplicable. Brown v. Lumbermen's Mut. Cas. Co., 49 Ga. App. 99, 174 S.E. 359 (1934).
 
ALLEVIATION OF HUMAN SUFFERING. --The purpose of the workers' compensation law (see O.C.G.A. § 34-9-1 et seq.) is to alleviate human suffering and to contribute to human need when accidental injury is suffered in the manner prescribed thereby. Lumbermens Mut. Cas. Co. v. Griggs, 190 Ga. 277, 9 S.E.2d 84 (1940).
 
IMMEDIATE FINANCIAL ASSISTANCE. --The workers' compensation law (see O.C.G.A. § 34-9-1 et seq.) attempts to provide immediate financial assistance for injured employees, without regard to whether or not the injury resulted from the fault of the employer, the single and only requirement being that the injury resulted from an accident arising out of and in the course of the employment. Slaten v. Travelers Ins. Co., 197 Ga. 1, 28 S.E.2d 280, answer conformed to, 70 Ga. App. 665, 29 S.E.2d 98 (1943), cert. dismissed, 197 Ga. 856, 30 S.E.2d 822 (1944).
 
SCHEDULED AND LIMITED RATE OF COMPENSATION. --One of the main objects of the workers' compensation law (see O.C.G.A. § 34-9-1 et seq.) was to enable an injured employee to recover from an employer according to a scheduled and limited rate of compensation, regardless of assumption of risk or of whose negligence caused the injury, thus assuring the employee of some compensation for the injury and assuring the employer that the employer's liability will be limited. Critchfield v. Aikin, 33 Ga. App. 668, 127 S.E. 816 (1925); Horn v. Planters' Prods. Co., 40 Ga. App. 787, 151 S.E. 552 (1930).
   The workers' compensation law (see O.C.G.A. § 34-9-1 et seq.) is intended to establish rates of compensation for personal injuries or death sustained by employees in the course of employment. Ocean Accident & Guarantee Corp. v. Farr, 180 Ga. 266, 178 S.E. 728 (1935).
 
REPLACEMENT OF COMMON LAW RULES. --The purpose of workers' compensation legislation was to do away with common law rules governing actions by employees under the law of master and servant, and to replace such an antique system with one that provided absolute liability of the employer and fixed compensation for accidental injury or death. Sands v. Union Camp Corp., 559 F.2d 1345 (5th Cir. 1977).
 
METHOD OF SETTLING DISPUTES. --The obvious intent of the workers' compensation law (see O.C.G.A. § 34-9-1 et seq.) was to substitute its procedure for the former methods of settling disputes arising between those occupying the strict relationship of master and servant or employer and employee. Denis Aerial Ag-Plicators, Inc. v. Swift, 154 Ga. App. 742, 269 S.E.2d 890 (1980).
   The design of the workers' compensation law (see O.C.G.A. § 34-9-1 et seq.) is to furnish speedy, inexpensive, and final settlement of the claims of injured employees. Continental Cas. Co. v. Caldwell, 55 Ga. App. 17, 189 S.E. 408 (1936).
   The workers' compensation law (see O.C.G.A. § 34-9-1 et seq.) abhors and shuns protracted and complicated litigation over the facts of any case. Continental Cas. Co. v. Caldwell, 55 Ga. App. 17, 189 S.E. 408 (1936).
 
HEALTH AND ACCIDENT INSURANCE. --Purpose of the workers' compensation law (see O.C.G.A. § 34-9-1 et seq.) was to substitute a method of accident insurance in place of common law rights and liabilities for substantially all employees. Slaten v. Travelers Ins. Co., 197 Ga. 1, 28 S.E.2d 280, answer conformed to, 70 Ga. App. 665, 29 S.E.2d 98 (1943), cert. dismissed, 197 Ga. 856, 30 S.E.2d 822 (1944).
   Workers' compensation is in the nature of health and accident insurance against injuries which arise out of and in the course of the worker's employment. Utica Mut. Ins. Co. v. Pioda, 90 Ga. App. 593, 83 S.E.2d 627 (1954).
   Workers' statutory compensation is not in the nature of damages awarded for injury, and is not intended to give full satisfaction for an injury; it is more like benefits provided ex contractu under a policy of insurance. Gay v. Greene, 91 Ga. App. 78, 84 S.E.2d 847 (1954).
 
LIFE INSURANCE. --Workers' compensation has never been like life insurance. Insurance Co. of N. Am. v. Russell, 246 Ga. 269, 271 S.E.2d 178 (1980).
 
MEANS OF ESCAPE FROM PERSONAL INJURY LITIGATION. --The legislature has endeavored by the workers' compensation law (see O.C.G.A. § 34-9-1 et seq.) to provide a means by which an employer and employee may, if they so choose, escape entirely from that very troublesome