.

In addition,
strength training in the person with a CNS lesion was
considered contraindicated, since it was believed
that strength training would increase tone problems
(Bobath, 1990; Davies, 1985).

The use of a side-lying position is often suggested as an

approach to inhibiting the effects of the asymmetrical
tonic neck refl ex on muscle tone, facilitating bilateral
symmetrical activities (Bobath & Bobath, 1984).