In Bland v. Workmen's Comp. App. Bd. (1970) 3 Cal.3d 324, the employee injured his knee on December 16, 1963, and was awarded temporary and permanent disability benefits. ( Bland v. Workmen's Comp. App. Bd., supra, 3 Cal.3d at pp. 326-327.) On August 23, 1968, the employee filed a petition to reopen the case, requesting " 'that the Appeals Board take such steps as may be necessary to a redetermination of this matter and for an increase in the benefits payable to petitioner on account of said permanent disability.' " ( Id. at p. 327.) The WCJ awarded additional permanent disability benefits. However, because of a worsening condition that required surgery, the employee petitioned for reconsideration, claiming his condition was not yet permanent. On reconsideration, the Board agreed and awarded the employee temporary disability benefits. (Ibid.) The insurer petitioned for reconsideration, claiming the Board lacked jurisdiction to award benefits for temporary disability because this had not been requested in the original petition. The Board agreed and reversed itself. ( Id. at p. 328.) The Supreme Court annulled the Board's decision. First, the court noted the language of the petition to reopen was sufficiently broad to encompass temporary disability. According to the court, the language requesting that the Board " 'take such steps as may be necessary to a redetermination of this matter' invited the Board to enter a jurisdictional area of unlimited expanse ... ." ( Bland v. Workmen's Comp. App. Bd., supra, 3 Cal.3d at p. 331.) The court explained: "The reference to 'permanent disability' constitutes an additional and further request, joined with the prior prayer by the word 'and'; it does not restrict the prior, and broader, prayer." (Ibid.) Finally, the court summarized: "In conclusion, 'we do not believe that awkwardness in allegation should constrict a worker's right to compensation. In many cases before the Board, applicants are not represented by counsel and lack advice as to procedural niceties. The applicant's claim is entitled to adjudication upon substance rather than upon formality of statement.' " ( Id. at p. 334.)