Simon Singh is preparing to announce his decision as to whether he will appeal or not.
So it is perhaps a good moment for me to step back and examine the wider legal context of this case, to take stock and to share some general observations with you.
I will also explain why I believe English libel law should be reformed in respect of public health and public safety issues.
(Please note it is English libel law - not UK or British libel law. Scotland and Northern Ireland have their own legal systems. Only Wales shares English law. Yes: it not even the entire UK's legal system which is the cause of international libel tourism and of the chilling effect.)
And I will make a friendly suggestion as to what the British Chiropractic Association should really do to protect their reputation.
1. The Reputation Of The British Chiropractic Association
I will start with - what is legally speaking - the very heart of the case: the reputation of the British Chiropractic Association.
It is this reputation which is supposedly at stake in this litigation, and it is this very reputation which the British Chiropractic Association is seeking to protect through this litigation.
On this basis, it may not have been a pleasant week for the British Chiropractic Association.
Their victory at the preliminary hearing does not seem to have played at all well either in the mainstream media or the blogosphere.
(On this, please see this excellent digest of coverage by Chris Kavanagh.)
And the coverage in such a beacon of the mainstream media as The Economist was probably what not the British Chiropractic Association, their media advisers, and their lawyers, were expecting.
It may even appear to some people that the reputation of the British Chiropractic Association itself has suffered, rather than been vindicated, by all of this. Some may say that its reputation could suffer more as this case continues.
If so, the British Chiropractic Association was warned about the potential adverse effects of this libel action (hat tip to Edd for reminding me).
As I was once told by the (probably) best media litigator in the City: a competent libel lawyer can tell you whether you have a case; but a good one will tell you whether you should actually bring it.
2. The British Chiropractic Association's Misconceived Libel Case
By various accidents and quirks of English libel law, the British Chiropractic Association was always in a strong position in this litigation.
I have always described their case as misconceived, but not weak.
BTW "Misconceived" is lawyerly and courtroom speak: but there is perhaps a shorter (and indeed recently much-analysed) word which can in my view be an almost-perfect synonym for every time a lawyer ever says something is misconceived.
3. How to Evaluate the British Chiropractic Association's Reputation: A Practical Approach
The British Chiropractic Association promotes chiropractic, a form of complementary and alternative medicine.
To paraphrase the Bishop of Southwark, such promotion of chiropractic is what the British Chiropractic Association does.
Chiropractic consists mainly of spinal manipulations, and so it is an activity which can be dangerous and may have adverse side-effects.
But it is a completely legal activity, and the British Chiropractic Association exists to promote it. There can be nothing wrong with this.
In its pamphlet - now seemingly withdrawn - "Happy Families" - the British Chiropractic Association stated:
"Birth trauma
Although a natural process, birth is sometimes traumatic for both mother and baby,
Chiropractic may help you and your baby recover from any birth trauma.
Treatment aims to relieve the stress that can affect your baby’s neck and head, especially if forceps or other medical assistance was involved, or if it was a breech birth.
There is evidence to show that chiropractic care has helped children with the following symptoms:
Asthma
Colic
Prolonged crying
Sleep and feeding problems
Breathing difficulties
Hyperactivity
Bedwetting
Frequent infections, especially in the ears"
Here chiropractic is not only being promoted for children but, on a natural reading, even babies.
Again, there is surely nothing too surprising - or necessarily wrong - with this because again promoting chiropractic is what the British Chiropractic Association does.
But note: chiropractic is here being promoted for children and babies not just for back pain, but for a wide number of ailments, including potentially very serious afflictions such as asthma and serious ear infections.
This is where I think the public interest becomes fully engaged in this legal case, and any rights that the British Chiropractic Association has in its reputation must become qualified by - and yield to - the priorities of public health and public safety.
This imperative is because the efficacy of the manipulation the spines of children (who almost by definition have not fully developed) and babies must be something in which there is a legitimate public interest.
This public interest is then amplified significantly with matters as potentially highly serious as asthma and frequent ear infections
As a lawyer would say: this requires "anxious scrutiny".
Now, at the time the Happy Families leaflet was produced, the British Chiropractic Association purported to provide scientific evidence in support of these propositions.
However, as my summary of Singh's defence indicated, this evidence was at best misconceived:
"1. Colic
Simon Singh lists a number of trials where Chiropractic has been shown to be ineffective: Olafsdottir (2001), Ernst (2003), Husereau (2003), Ernst/Canter (2006).
He then provides a detailed critique of the Wiberg (1999) trial cited by the BCA, and in particular where it did not meet most of the standards required and expected of a properly-done clinical trial.
2. Sleeping Problems
Simon Singh is unaware of any published clinical trials investigating (let alone supporting) the efficacy of Chiropractic in dealing with sleeping problems.
He points out that the BCA's reference is to a page in a book (Anrig & Plaugher) discussing two case reports.
3. Feeding Problems
Similarly, Simon Singh is unaware of any published clinical trials investigating (let alone supporting) the efficacy of Chiropractic in dealing with feeding problems.
He points out that the BCA's reference is to a page in a book (again Anrig & Plaugher) discussing feeding habits of parents, with no research or evidence.
4. Frequent Ear Infections
Simon Singh is also unaware of any published clinical trials investigating (let alone supporting) the efficacy of Chiropractic in dealing with frequent ear infections.
He points out here that the BCA reference is to an unpublished ongoing trial.
5. Asthma
Simon Singh lists a number of trials where Chiropractic has been shown to not be effective: Balon/Aaker (1998), Balon/Mior (2004), Hondras (2005) and Ernst/Canter (2006)
He then points out that the BCA's citation (Kukurin) is to a letter to the editor commenting on a pilot study.
6. Prolonged Crying
Simon Singh is also unaware of any published clinical trials investigating (let alone supporting) the efficacy of Chiropractic in dealing with prolonged crying.
He points out here that the BCA's citation is to a non-publicly available paper (Budgell) which looks at the experience of chiropractors and does not look at clinical trials.
After these detailed expositions, Simon Singh then sets out the risks for children who receive Chiropractic treatments for these ailments rather than those which have been subjected to clinical trials."
Now, at this stage, I invite you to re-read the excerpt from the British Chiropractic Association's Happy Families and the summary of Singh's defence.
Concentrate on each particular ailment mentioned and what Singh was stating in response, and whilst you do this, bear in mind that all this is in the sensitive context of spinal manipulations of children and babies.
Everyone following this case should be aware of the exact claims the British Chiropractic Association were making and what Singh had to say about the evidence they had put forward to support each of those claims.
So to return to the reputation of the British Chiropractic Association.
What would any reasonable and objective person think of the British Chiropractic Association, and of its promotion of chiropractic to children and babies, if Singh's defence is actually valid?
Of course, we may not now know if it is "legally" valid, because of the ruling in the preliminary hearing. And so for now the situation is worryingly left uncertain and unsatisfactory.
But, as Heresiarch wisely pointed out in a comment on an earlier post on this site, the formal litigation is (unless appealed) now about alleged fraud and not treatment.
There can surely now be no problem with the British Chiropractic Association now dealing fully with the points raised in Singh's defence.
So I urge the British Chiropractic Association to respond publicly and swiftly to Singh's critique of its supporting evidence for the Happy Families contentions, regardless of what happens to this misconceived libel litigation.
If the British Chiropractic Association does not respond, it may be that reasonable and objective people can draw their own conclusions about what the British Chiropractic Association did with the Happy Families leaflet.
Here the reputation of the British Chiropractic Association may really be at stake.
4. Why Can The British Chiropractic Association Sue For Libel When it Not Even A Real Person?
Now I turn to the counter-intuitive point that the British Chiropractic Association can sue in the first place.
I regard this part of defamation law as Alice in Slanderland.
It is a legal fiction that companies and other corporations have "personality". As Jules Winnfield says in Pulp Fiction, personality can go a long way.
And the presumption in English law is that those with natural and "legal" personality have exactly the same standing. Of course, companies don't really exist: they have no tangible existence.
As the (sometimes - though not always - brilliant) English judge Lord Denning said, companies have "no body to be kicked and no soul to be damned". In my view, they should also have no reputation which can be sued upon.
Or if they should, it should be a narrow right to sue similar to "slander to title" - so if I alleged (which I do not) that the British Chiropractic Association was really promoting homeopathy when it's objects state it should be promoting chiropractic, it may perhaps have a legal remedy. After all, the Bishop of Southwark is not the Bishop of Liverpool.
Some years ago, in an important decision for free speech, the English courts ruled that public bodies (or at least statutory corporations) could not sue for defamation: this is the Derbyshire case. Sadly, more recently, the rights of trading companies to sue for defamation - such as Tesco - have been upheld.
The British Chiropractic Association is not Tesco. It doesn't even have shareholders. It is a "company limited by guarantee", existing to be a representative body of a profession.
It can sue for defamation simply because of the historical quirks of English libel law. But, in my view, the circumstances in which such a "legal" person can sue for defamation - if any - should be limited.
Singh is intending to make this "corporate point" if his case continues, regardless of the result of any appeal (or non-appeal).
I think he should.
5. Libel Reform and Public Health and Safety: A Proposal
But I would go even further than the "corporate point".
In the field of public health, it really should not be open for any provider or promoter of treatment - human or corporate - to sue for defamation in respect of their provision or promotion of those treatments, unless they can show malice by the defendant.
(And the same goes for public safety.)
The rights of providers and promoters to their reputations - however legitimate - are less important than ensuring that there is full and frank discussion of the merits of such treatments.
There should be a change.
And such a change is all perfectly possible in English libel law.
There is a doctrine of "qualified privilege" which protects defendants in a range of sensible contexts. It covers, for example, complaints to the police or certain communications between employees. It is now even being extended to cover "responsible journalism" with the so-called "Reynolds Defence" .
With qualified privilege, claimants with any legitimate right to their reputation can still sue for defamation if they can show malice (a high hurdle in English law).
But it is the claimant which has the burden of proof, not the defendant.
Qualified privilege has the underlying policy objective of ensuring candid but non-malicious debate.
It should be urgently extended to cover matters of public health and public safety.
Singh's case had not really progressed far enough for this "qualified privilege" point to be raised. The case has only got to the preliminary hearing on meaning. This is more a point for a further hearing or the full trial, even if last week's ruling is not overturned.
I hope the point is made: we desperately need a "Simon Singh Defence" to complement the "Reynolds Defence".
6. My Friendly Suggestion for the British Chiropractic Association
As for the British Chiropractic Association, I would remind them that libel should be about reputation, and libel litigation should be about effectively protecting such reputation.
Their press release states that the result of this preliminary hearing on meaning has "vindicated" the British Chiropractic Association (though of course such a meaning remains untested by full trial and so any claim for vindication is actually misconceived).
However, with such a vindication, perhaps they should now consider dropping this case?
The correct response to Singh's challenge on the evidential basis for chiropractic for children and babies with the non-back related ailments should always have been for the British Chiropractic Association to hold their evidence up to scrutiny.
It remains an important matter for public concern. The public interest here cannot be withdrawn like an unwelcome and misconceived leaflet.
As Frank Frizelle said to the New Zealand chiropractors and their lawyers in a similar case:
"Let’s hear your evidence, not your legal muscle."
And providing the hard evidence is what the British Chiropractic Association should now do: that is, if their purported interest in protecting their reputation is not entirely [blank].
Saturday, 16 May 2009
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22 comments:
I like your last point; why don't they just show us the evidence which proves chiropractic works? If 'normal' medicine was in a similar situation they would just provide evidence, it would surely be a simpler and cheaper way to prove Simon wrong.
Fantastic article! I sincerely hope someone at the BCA involved with the case gets round to reading it.
I also fully agree that this is quickly turning into a very damaging case for the BCA's reputation.
When compiling the link round up I intended to include a section for pro-BCA articles and posts but I haven't been able to find any aside from throwaway remarks in comment sections.
There may be some but if so they are being drowned under the articles expressing support. So if I was the BCA I wouldn't be looking to drag this out further.
Posting a response to Simon's points and engaging in a debate over the evidence would be the decent and you would imagine logical step for the BCA. However, given that they didn't go down this route initially I don't hold out too much hope for the future.
Anyway, great job again I'll add this to the list!
I have been following this case as I was contacted by Simon Singh at one point regarding one of my publications and became interested in story behind it. While the subtleties of defamation law are not my forte, as a medical scientist I would say that efficacy and danger are relative terms and open to interpretation. It appears, however, that the term bogus is more straightforward. I agree that the claims in the brochure are overblown and most appear to be lacking in any published support, it is however incorrect to say that, for example, chiropractic has been shown to be ineffective for colic because there are four publications that failed to detect a relative benefit from the treatment vs. one that did. Failure to demonstrate a difference between therapies in a controlled trial is not the same thing as proving the therapy is ineffective.
Moreover, the concept that a treatment has to be subjected to a randomized controlled trial in order to be deemed effective is not accurate. A group of expert chiropractors can agree that a treatment is effective based upon experience, and this is considered evidence of efficacy, albeit a low ranking level.
The biggest problem that I see with the "bogus" issue is the claim that chiropractic "can be dangerous." There are no data to support this claim aside from the anecdotal reports of injuries in the literature and an easy acceptance of such claims from some parts of the medical and scientific community, in which it cannot be denied that there is a double standard. The literature does not delineate between whether the injury resulted from an appropriately delivered chiropractic treatment or if it was the result of negligent patient care. This must be established prior to deeming a therapy dangerous, rather than some therapists incompetent or negligent. For example, one would not say that as a general premise surgery is dangerous because a surgeon performing an appendectomy stabbed a patient in the eye with a scalpel.
There are a number of common medical treatments for a variety of conditions that have no evidence of efficacy but that do have known complication rates that are surprisingly high, yet the term "bogus" would not be used to describe their use, and if it was one would expect a bit of an outcry.
Had Simon Singh kept his claims more modest - simply saying that the birth trauma is not demonstrable diagnostically and that the efficacy of treatment for the conditions is unproven, I would have been behind him 100%. I don't know that the term "bogus" means that fraud is occurring knowingly, but it can't be argued that if the term is applied to a medical therapy that it doesn't sound like a complement.
The BCA's press release is carefully worded. Their president stated:
“The BCA brought this claim to preserve its integrity and reputation. I’m delighted that the Judge has vindicated the BCA’s position.”
What was vindicated by the judge was the BCA's claim that Simon Singh's remarks were defamatory statements of fact, not comment. However, by mentioning in the previous sentence that the BCA's goal is to preserve its reputation, the over-all impression is given that this too has been vindicated.
I agree with Ben; I don't see much dignity to preserve for the BCA. Their claims are too easily attacked as baseless and overblown. On the other hand, how does a minority and competing health care field tell the public about a therapy they think is effective? There's a fine line to walk between good health care and overly enthusiastic and inflated claims in support of a marketing approach. In the US medicine is crossing this line nearly as often as alternative medicine practitioners in a attempt to get out of managed care and into cash practices.
Perhaps the economics of chiropractic in the UK is the largest driving force behind the claims.
Dr Michael makes a very relevant point- many conventional medical approaches are unproven and would not stand up to scrutiny. This would be particularly true if you were to examine techniques used by osteopathy and physiotherapy.
The opinions of many anti CAM bloggers appear so entrenched and biased that it is unlikely that any professional association or profession would consider opening a dialogue with them.
I agree with Jack of Kent (here, but in Spanish, I'm afraid). Giving the damage -I would say "self-inflicted"- that this case has done to its "reputation", their best option now would be drop de case or accept a settlement, even a simbolic one. But my doubt, and maybe their's also, is if this would put a stop to the critics they are receiving. Maybe if they act quickly and drop the case ASAP they would be able to confine the critics to the blogosphere -more or less- but if the news keep spreading among the media their only option would be to fight for a victory in a full trial, hoping that the public will see it not only as a vindication of their reputation, but also as an assertion of the efficacy of their treatments.
I cannot find anything to complain of in Eady J's decision.
Likewise, I have no problem with a law of libel which requires the maker of a statement to prove that it was true and/or that he had a duty to make that statement to someone who had a duty to hear it (privilege). After all, if the statement was 'you damaged my car in an accident', he would have to prove that.
But I like your suggestion that there should be something like a 'public interest' defence.
I also like your suggestion that commercial corporations (which would include the BCA, right) should not be able to make ordinary defamation claims, only a 'commercial tort' variety.
But wouldn't Mr Singh still be screwed in both those circumstances? Isn't his real problem that, although he is a professional writer, he apparently didn't understand the full implications of using the word 'bogus' in his article?
Did he really intend NOT to suggest that there's something suspicious about such people promoting their woo-woo treatments in the absence of anything like convincing evidence of efficacy?
Jack,
Great post - I subscribe to nearly everything you say.
Unfortunately, I don't think this case has received that much coverage and I don't think that much damage has actually been done to the BCA. In any case, it is far less damage than the predictable tabloid outrage had a 'conventional' scientist sued an alternative medical grouping.
xD.
Excellent summary, Jack. I have finally posted my own updated musings (though nothing like as forensic as yours, needless to say).
As you have probably noticed, and I pointed out briefly here, the same debatable claims made for chiropractic in Happy Families are more or less omnipresent - and frequently reproduced verbatim - on the websites of individual chiropractors who are BCA members. I see one of the commenters over at the Economist noted the same thing. I would presume this is because many or all of these practitioners "adapted" the wording of the leaflet (or in some cases simply reproduced it) for their own websites.
One might in turn logically infer from this that the BCA's member chiropractors individually and as a whole are fully signed up to these claims. So they will not disappear by the BCA's removing the leaflet. They are set to remain as central to any discussion of the public health issue of:
"What sort of evidence do chiropractors really feel is adequate to support the use of their treatments? And do the rest of us feel that that is adequate?"WRT to the comments above about "entrenched attitudes" of anti-CAM bloggers; a point here is the overwheming certainty of belief with which CAM treatments are pitched by their proponents, even (especially) largely absent any convincing evidence of efficacy. I really do not think you get this in mainstream medicine any more, as doctors (and other mainstream folk) are PROFESSIONALLY AND ETHICALLY OBLIGED to be circumspect and honest about how they present risk / benefit and similar issues to you. I personally do not think CAM people do the same. Too often they seem to proceed from a standpoint of:
"This therapy of mine cannot do harm, and can only do good, so the specifics of "how much harm/good?" are "how do you know that?" are irrelevant to my discussion with the patient"That, I suggest, is a major reason why they get short shrift from the sceptical fraternity, especially within medicine.
Interesting use of the word 'bogus' in tonight's Panorama. Sorry to sound naive but was this being used in a similar context to Mr Singh's case?
Simon should:
First think about protecting himself
Second: fight back, with our support. Make the BCA bitterly regret their libel case. Something to think about
Some of the comments regarding CAM and mainstream medicine are a bit broad for my tastes; there are good, bad, and mediocre practitioners in both camps. Conventional medical practitioners are less likely to oversell a treatment, but who needs to worry about selling facelifts and breast augmentation when the popular media is doing it for you. Still, disappointed, sickened, and even killed patients result from these procedures.
This isn't a black and white issue and shouldn't be reduced to one.
A quick search for "bca 'happy families' " shows the leaflet is still available on at least one UK chiropractic website.
Some have commented that the use of the phrase "happily promoted" is what has caused Singh's difficulties, but seriously, how else does anyone think the benefits would be promoted? Sarcastically, frumpily, disparagingly, lovingly, ironically, playfully...? One imagines the BCA were happy to promote perceived benefits of chiropractic.
I must disagree with Dr. Freeman's viewpoint. I think this is a false equivalence.
If somebody made a claim from ignorance that breast enhancement surgery cured asthma, or carried no risk, then it would be comparable. But so long as the risks are made clear at the outset, and the consequence of the surgery are made clear, then it is not the same thing at all.
And yes, to my mind, this is a black-and-white issue.
Competence of practitioners is another issue that applies to all fields, but that cannot falsify the key distinction being made above; raising competence issues is a red herring and an attempt to muddy the waters.
On a wider note, I disagree with JoK's view that a body such as the BCA or Tesco's cannot have their reputation damaged per se. Corporations have in their accounts a valuation of goodwill, which in many ways puts a value on their reputation. However, I believe that corporations must reflect any such damages in their goodwill account entries, and that goodwill clearly cannot drop below zero.
(I add a caveat that I know little of libel law, so I may have missed a legal subtlety in Jack's argument)
I take Spence's point as I did not make myself clear in my last post; what I intended to say that benefit to harm ratios are variable in both CAM and allopathy for various procedures performed by different practitioners, and that it is erroneous to say that CAM is monolithically bad or that allopathy is equally good.
It is not, in my opinion, reasonable to conclude that a claim of efficacy and safety by trained and experienced practitioners is "bogus" because it is unpublished, regardless of the type of practitioner. It is reasonable to say that the claim is unvalidated, however. A claim that asthma is helped by chiropractic treatment that is made by a chiropractic organization without validating literature is no more nor less than an unvalidated claim of efficacy. Whether the BCA is required to show supporting documentation by the dictums of an antagonistic medical profession, an attempt to improve their standing in the eyes of science, or simply to be able add that their claims are validated with supporting literature is a different issue.
There a numerous instances of medicines and surgeries that have been found to be more effective than other medicines or surgeries by randomized controlled trials and yet in reality the beneficial effect is minimal or the net benefit is negative because of undescribed and sometime undisclosed risks (like with Vioxx).
This is what I meant by it's not black and white.
Sorry for the long post.
Yes, but...
The difference is that in medicine an unvalidated claim of efficacy would be seen (at least by most people) as something urgently requiring proper validation.
I do not see the same desire to test whether things work, using the best and least subjective methods, in CAM modalities. The practitioners and their associations are prepared to play at it in order to help their demands for "equal status in healthcare", but their commitment routinely disappears when negative results appear. Then it is back to cherry-picking the studies with the results they prefer - as with chiropractors and things like colic in infants - or insisting on some version of "Your RCT cannot assess my complex intervention".
This happens too regularly to be coincidence, in my opinion.
I would have more time for Dr Freeman's viewpoint if I saw evidence, for ANY CAM modality, that its practitioners or their professional bodies are really committed to sorting out the things their therapy might, or even does, work for with an acceptable risk-benefit balance, from the things that it DOESN'T work for.
Instead, their response when someone draws attention to the discrepancies seems to be to pick up the phone and call a libel lawyer. You may draw your own conclusions.
I have read a lot of journal articles by Edzard Ersnt as well as some by Simon Singh. I cannot help but wonder if the "bogus" word was the penmanship of Ernst rather than Singh and that Singh has now been caught up in Ernsts' adgenda, rather than his own analysis of the chiropractic profession.
If one was to look at the peer review literature into the "medical" treatment of conditions such as enuresis, colic and asthma, one would see that the efficacy of their use is no better than chiropractic. In fact some of the drugs and treatments are downright dangerous. I would imagine many medical practitioners cringing at the idea of having to give evidence in court as to the "scientific" validity of some of the care they give. Clinically it may work, but the reasons may not be known.
The chiropractic profession was scrutenized in 1979 with the New Zealand Commission if Inquiry. This extensive report has yet to be "bettered" or superceded by anything equivalent.
Perhaps there should be an Inquiry into the validity of the treatment of neuro-musculo-skeletal conditions by physiotherapists, osteopaths, orthopaedic surgeons and "medical manipulators". As an example, the use of therapeutic ultra-sound has been proven to be useless. Yet it is still extensively used by physiotherapists. Is this scientific?, Is this good health care?
These are just a few of the inconsistencies I see in the arguments raised by some of the bloggers. In otherwords, what we are seeing is "selective information dispersal", with no real balance.
Other than pointing out that a "good" libel lawyer will tell you whether or not you should file a case (or an appeal) you fail to address the financial issues.
If Mr. Singh has money to burn, or if someone somehow can pay his (and more likely than not, his opponent's) fees, then by all means. But why should he personally risk ruin?
This is a great information to make people be in the know. I always value people who add value to the information available to educate their readers.
I find that Dr. Aust's comments tend to be a bit of the straw man type. He (or she) states a willingness to be more tolerant of my point of view if ANY CAM (sic) was attempting to sort out the efficacy and risks of what it does. This is a baseless complaint; if one searches PubMed for the word "chiropractic" nearly 5000 publications will be listed. Acupuncture produces more than 14,000 hits, and homeopathy nearly 4000. Certainly, not all of these publications are supportive of this or that therapy; it is reasonable to state, however, that they are not homogeneously negative. On the other hand, the proportion of commonly performed allopathic procedures that have not been validated through RCTs or that have not been found to be particularly effective ranges from 50 to more than 80%, depending on the field of practice. Dr. Aust continues to espouse an "allopathy good and validated and CAM bad and non-validated" arrogance that simply is not justified, and only serves to perpetuate the reputation of traditional medicine as antagonistic to CAM. Broadly negative characterizations of entire fields of health care practice based only on one's prejudices do nothing more than perpetuate the feeling amongst CAM practitioners and their patients that there is a war on with traditional medicine. This pernicious attitude hasn't worked in the past (CAM use is at an all time high) and won't work in the future.
It is the most susceptible part of the body towards injuries. Sitting in one pose for a long time may also hamper the health of the neck and lead to serious problems throughout the body. Neck pain can be really severe in cases where the causes are multiple.
Moshen Zargar
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