Inconsistencies between a plaintiff's oral testimony and histories recorded by medical practitioners do not necessarily undermine the plaintiff's credit, and a trial judge is entitled to discount such inconsistencies for well-established reasons including that the medical practitioner was not cross-examined, medical histories serve a different purpose from establishing liability, and the recorded material is a summary rather than verbatim. A ground of appeal alleging inadequacy of reasons will only be sufficient where the appellate court is unable to make its own findings, and the obligation to refer to evidence is engaged only by evidence that is 'important or critical' to the determination.
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