The 'substantial contributing factor' test in s 9A(1) of the Workers Compensation Act 1987 (NSW) is less stringent than the 'arising out of' employment test. 'Substantial' means 'more than minimal, large or great' in a relative sense. The absence of employment characteristics in the activity causing injury is relevant but not determinative. A worker need not prove that employment created any special danger, employment risk, or added peril. Pre-existing constitutional predisposition does not preclude employment being a substantial contributing factor.
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