Expert medical reports relied upon in the Workers Compensation Commission must explain the factual basis for opinions and not merely assert conclusions; a bare ipse dixit carries no weight even in a tribunal not bound by the rules of evidence. The weight of expert evidence is not a discretionary matter reviewable only on House v The King principles but is susceptible to review on appeal in accordance with principles governing appellate review of findings of fact. An Arbitrator who suggests an amendment to a claim and then determines the matter in accordance with that amendment does not thereby demonstrate actual bias, provided the Arbitrator's mind remained open to persuasion.
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