An 'ordinary recess' under s 11 of the Workers Compensation Act 1987 (NSW) can occur during a continuous 24-hour period of employment; the relevant question is whether the interval can be characterised as occurring during the period of employment rather than when the employee is off duty. Medical reports that express a conclusion on causation without identifying the factual basis for the opinion or explaining the reasoning process are bare ipse dixit and carry no weight, even in a specialised tribunal. A specialised tribunal judge cannot use institutional knowledge of back impairments to infer the unstated basis of an expert's opinion so as to satisfy the Makita test. When determining the s 9A substantial contributing factor requirement, the judge must differentiate between distinct mechanisms of injury, explain why competing expert opinions are rejected, and expose the reasoning demonstrating that the contribution was substantial.
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