Apparent inconsistencies between histories recorded by health professionals and a plaintiff's oral testimony must be approached with caution, having regard to the circumstances of the consultation, the manner in which the history was obtained, the accuracy of the recording, and the differing purposes of clinical and forensic exercises. A trial judge should not uncritically adopt an expert psychiatrist's exercise of cataloguing apparent inconsistencies in a plaintiff's histories as a basis for adverse credibility findings. The correct approach to assessing psychological injury claims requires comparison of the plaintiff's pre-injury and post-injury functioning, with particular attention to contemporaneous treating records as the most reliable guide.
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