A finding that injury occurred 'in the course of employment' does not normally lead to a finding that employment was a 'substantial contributing factor' under s 9A(1) of the Workers Compensation Act 1987 — the former is temporal, the latter causal, and s 9A(3)(a) expressly precludes treating the former as sufficient for the latter. Where a worker engaged in recreational activity that predated the employment, the decision-maker may have regard to the pre-employment practice as relevant to the causal linkage between employment and injury. The Badawi error of approaching s 9A from the perspective of the non-employment activity is not committed merely because the decision-maker considers the activity in which the worker was engaged at the time of injury.
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