Incidents involving Robbie Rochow and Richie Fa'aoso have been raised in James McManus's Supreme Court case against the Newcastle Knights.

Lawyers acting for James McManus are seeking the medical records of former Newcastle players Richie Fa'aoso and Robbie Rochow as part of the former State of Origin winger's landmark concussion case.

McManus became the first Australian sportsperson to launch legal action against a sporting club after commencing action over the Knights' handling of his concussions.

LAW SUIT: James McManus

LAW SUIT: James McManus

The case was back in the Supreme Court on Thursday after the defence filed a motion against the subpoenaing of the medical records of McManus' teammates. It's understood the defence is arguing such a move would broaden the case beyond a reasonable scope.

Newcastle's handling of concussions, including those suffered by Fa'aoso and Rochow, is expected to form a crucial part of McManus' case. The Knights were roundly criticised when Fa'aoso was knocked senseless in a loss to Manly in March, 2011, but continued to play.

CONCUSSED: Robbie Rochow.

CONCUSSED: Robbie Rochow.

The image of Fa'aoso stumbling across Brookvale Oval in an attempt to regain his footing prompted the NRL to review their concussion policy. A day after the game, then-Knights coach Rick Stone said Fa'aoso was a player capable of recovering quickly from a head knock.

"Richie can look untidy when he gets knocked out but he comes to fairly quickly," Stone said. "Sometimes giving a bloke a couple of minutes to clear his head doesn't look good on TV but . . . I wanted to give him a minute or two to reassess where he was at."

In hindsight Stone conceded he should have replaced Fa’aoso immediately.

CONCUSSED: Richie Fa'aoso.

CONCUSSED: Richie Fa'aoso.

"For player safety, Richie probably should have come straight off on the weekend, there's no doubt about that," Stone said. "If I had my time again, I would definitely do that. But sometimes you leave them out there to see if they can get back into the game and you don't have to make an interchange."

Those comments wouldn't have been lost on McManus' lawyers, who claim the Knights were negligent in their duty of care.

Another incident of interest to McManus' legal team involves Rochow. The forward copped two head knocks during a loss to Penrith in round 19, 2013. The Knights were criticised for their handling of the situation, prompting then-coach Wayne Bennett to hit out at the "drama queens".

"I don't really need a whole lot of procedures for me to do the right thing by players with concussion," Bennett said after the Rochow incident.

"I've done it all my coaching life, so there's no chance that those players will play on the weekend if there's any doubt about their health."

It's understood Stone and perhaps even Bennett could be subpoenaed as the case continues to unfold.

In a statement of claim filed to the court, it's claimed Newcastle should have forced McManus into retirement in 2013 but the club's failure to do so resulted in him suffering at least 10 concussions and permanent brain injury. It's claimed McManus was permitted or urged to continue his career despite displaying traumatic brain injury symptoms including "confusion, disorientation, memory impairment and balance disturbance".

McManus is seeking damages, costs and interest after suffering "traumatic brain injury". He was employed by the Knights in a commercial role after he retired but parted company with the Knights earlier this year, ending the awkward situation of suing the club he was working for.

Former Parramatta forward Brett Horsnell became the second former footballer to begin legal proceedings over the club's handling of concussions.