6.2 From the Claimant's point of view the medico-legal experts will need the records to determine the Claimant's pre-accident state of health and to discount any other conditions. The post accident records are commonly summarised by the Claimant's medical expert who sets out the injuries which were initially diagnosed and the treatment received at hospital and elsewhere. The treating doctors' records should recite the history of the resolution of the symptoms and are useful to corroborate the complaints made by the Claimant. Where possible the diagnoses of the treating doctors are relied upon as support for the medico-legal experts own diagnosis.

6.3 From the Defendants point of view the medical records are also vital. The pre-accident GP and hospital records often evidence pre-existing conditions, such as degeneration of the spine with complaints of pain, which may enable the Defendants' medical expert to put into perspective the post accident complaints.

6.4 All other matters being equal, a Claimant with a back injury and no prior back pain will probably receive higher damages than one with a long history of back pain. If the treating doctors' records show doubts about the veracity of the complaints or raise the issue of a compensation neurosis or psychiatric conditions the Defendants will be alerted to the possibility of malingering.

6.5 In some cases the post accident medical records will disclose a supervening medical condition, for instance a wholly unrelated heart condition, which would have disabled the Claimant in any event. Such supervening conditions will radically alter the level of damages awarded.

6.6 The following medical records are most commonly sought;

- GP's notes: records for a substantial period before the accident and ever since should be obtained. The older ones will be on Lloyd George cards. The newer ones on computer.

- GP's correspondence: likewise, copies of the correspondence for a substantial period before the accident and ever since should be obtained. These will give a more detailed insight into the GP’s views of the Claimant's conditions than the