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Ali v Ageas (2016) – Lawtel AM0202980 is helpful. "C confirmed that his physiotherapy treatment, for which he claimed £645, had taken place via telephone. DJ Gray stated that, “It is totally unreasonable. Physiotherapy is a hands on physical thing, hence the name. ... It is a woeful failure to adequately describe. This is totally misleading – you would assume from this [the invoice] that it was hands on but the idea that it has been done by phone is breathtaking - Nil”.