(dissenting). I cannot agree that the law is as clear as the majority opinion suggests. At least three cases suggest that the one year back rule should apply in the instant case. In Loucks v Bauman, 356 Mich 514; 97 NW2d 321 (1959), plaintiff suffered an employment-related amputation of one leg and was paid specific loss benefits pursuant to the schedule. Some time after those benefits expired, he returned seeking total disability benefits, arguing that his other leg had also been rendered unstable and unusable by the injury to the left leg. In an opinion signed by three justices, Chief Justice Dethmers concluded that the instability of the other leg had existed since the date of the original injury, was not a "further development”, and thus the plaintiff was requesting "further compensation” for his original injury which should be limited by the one-year-back rule. This view carried the day, thanks to a separate concurrence by Justice Edwards.
*519The next decision applying the one-year-back rule was Adcox v Northville Laboratories, Inc, 381 Mich 600; 166 NW2d 460 (1969). The plaintiff in that case suffered a hip injury and received voluntarily paid total disability compensation for slightly more than a year. Payments were then stopped by the employer and several years went by before the plaintiff filed a petition for more total disability benefits. That petition alleged that the hip injury had further degenerated into a condition of "aseptic necrosis”. The WCAB found that this was a new disability which was not subject to the one-year-back rule. However, the Supreme Court reversed that conclusion on appeal in an opinion which is fairly summarized by the following quotation:
"The doctor’s quoted testimony reads fairly if not persuasively that plaintiffs 1962 pain and subsequent disability was due to aseptic necrosis; that such necrosis is a not-unusual result of a hip fracture such as was sustained the previous year by plaintiff; that it 'arose as the result of the fracture with damage to the blood supply to the head of the bone,’ and that 'basically it is the result of the original trauma.’ It supports the quoted finding as well as the final conclusion reached by Division 1 of Court of Appeals and calls for a determination here that plaintiff failed to prove that he has suffered a 'further development’ within meaning and purpose of the cases which Justices Dethmers and Edwards considered in their concurring opinions of Loucks v Bauman (1959), 356 Mich 514, 529.” 381 Mich at 610.
For the stated reasons, the Court applied the one-year-back rule to limit the plaintiff’s recovery. The case appears to say that where the later difficulties are the "not unusual result” of the original injury, the plaintiff has not shown a "further develop*520ment” of the sort which will avoid application of the one-year-back rule.
The third and strongest case for application of the one-year-back rule is Baldwin v Chrysler Corp, 67 Mich App 61; 240 NW2d 266 (1976), lv den, 396 Mich 862 (1976). Plaintiff suffered a leg amputation and was paid specific loss benefits. Thereafter, he obtained other employment which lasted for approximately two years. When that employment ended, plaintiff petitioned for "total and permanent disability” benefits, alleging loss of industrial use of both legs.1 Plaintiff was found to be "totally and permanently disabled”, but the one-year-back rule was applied to limit the amount of benefits.2
Baldwin is similar to the present case in that the plaintiff was seeking "total and permanent disability” benefits after previously receiving benefits of another type. I disagree with the majority that because plaintiff’s condition in Baldwin was the same at all times whereas, in the present case, plaintiff’s condition had deteriorated, Baldwin is distinguishable. I believe this stretches language beyond reason. In plain and simple language, the statute provides that where compensation benefits have been made "and an application for further compensation is later filed with the bureau, no compensation shall be ordered for any period more than one year prior to the date of filing of such application”. Based on the commonly understood dictionary use of the word "further”,3 the statute at least semantically covers the present situation. *521This plaintiff suffered a back injury and was paid benefits for the resulting disability. He was, is, and probably will remain totally disabled from that injury. By pointing to specific symptoms of that injury, he has been able to establish "total and permanent disability” but the fact remains that all of his petitions have sought benefits for continuing disability traceable to the same injury. He wants and is entitled to something additional for the same injury. I believe that this is what the Legislature had in mind when it used the phrase "further compensation”.
A principal purpose of the one-year-back rule is to provide timely notice to defendants of the claims which will be made against them.
"Obviously this section was passed to guarantee a defendant prompt notice of claim for subsequent compensation, and to prohibit imposing on a defendant the burden of defending a stale claim.” White v Michigan Consolidated Gas Co, 352 Mich 201, 212; 89 NW2d 439 (1958).
Defendant employer in this case had notice of the plaintiffs injury from the day it occurred. However, defendant appellant, Second Injury Fund, the party actually aggrieved by the decision below, did not have notice of the potential claim against it until the petition was filed. This is an additional reason—not present in most of the other cases— for applying the one-year-back rule on these facts.
Application of the one-year-back rule is not—as the majority opinion implies—inhumane or harsh in application to employees. Any employee who suffers an injury for which he is paid compensation and who later suffers additional consequences of the original injury is fully protected upon promptly filing for additional compensation. The employee is entitled to the additional benefits dating back one year from the date on which the *522petition for additional benefits was filed.4 I would reverse in part the decision of the WCAB and remand for entry of an order for differential benefits commencing September 5, 1972, rather than commencing September 5, 1971.5
Prior to the amputation, plaintiff’s other leg was essentially useless due to a polio disability.
The Baldwin opinion states that the one-year-back rule is a limit on the Workman’s Compensation Bureau’s authority to award benefits, not a statute of limitations. That statement is incorrect but it does not affect the substantive holding in Baldwin. See White v Michigan Consolidated Gas Co, 352 Mich 201; 89 NW2d 439 (1958).
The dictionary definition of "further” is "going or extending beyond what exists. Additional”. Webster’s Third International Dictionary (1965 Edition).
Of course, the additional compensation may not extend back one year where the date of “total and permanent disability” commences less than one year back from the date of the application for benefits therefor. The principal advantage in seeking a determination of total and permanent disability is that, if successful, the Second Injury Fund is required to pay differential benefits. MCL 418.521(2); MSA 17.237(521)(2).
The WCAB found that the two-year-back rule applied and held that plaintiff was entitled to differential benefits beginning two years before the filing of his application.