Extraordinary Light Phenomena

The experience of a seeing an extraordinary light, quite different from ordinary physical light, seems to be a rare but universal human experience. This special light is described as being much brighter, more intense, and more radiant than natural light, appears in various forms and shapes, and is sometimes perceived as an autonomous entity - a being of light. Some are in communication with it, receiving advice or guidance. Others feel embraced by it, experiencing warmth, comfort, love, or healing. Such events can have a life-changing or even transforming quality. For most people the fear of death vanishes, and for some, the presence of this non-physical light confirms a belief in some sort of continuation of consciousness beyond death.

Light and Soul: Traditional Beliefs and Early Philosophy

Two Types of Light

Traditionally, a distinction is made between physical or ‘outer’ light that is perceived with ordinary eyesight, and non-physical light that depends on some kind of ‘inner sight’, like visions in dreams. Some languages make the disctinction explicit: for instance Bulgarian has videlina for physical light and svetlina for non-physical, spirit light.

Around 500 BC, the pre-Socratic philosopher Parmenides spoke of light as a symbol for truth and being. Plato mentioned an archetypal light, an idea that six hundred years later was followed up by Plotinus and a century after that by Bishop Gregory of Nyssa. Goethe expressed it in his famous words:

Waer’ nicht das Auge sonnenhaft,
Die Sonne koennt’ es nie erblicken:
Läg’ nicht in uns des Gottes eigene Kraft
Wie koennt’ uns Goettliches entzüecken?

(Had the eye not sun-like quality
Ne’er behold the sun it might
Did god’s strength not dwell in you and me
How were we to enjoy divine delight?)1

Unusual Lights Across Cultures

Unusual, brilliant and non-physical lights have been described throughout the world: Shamanic lights during initiation, the ‘pure’ light of the Upanishads in India, the Buddhist’s ‘white light’, and the light of illumination and enlightenment in the Jewish, Christian, and Mystic traditions.2  Other strange lights range from earthlights in the context of earthquakes3 to orbs and UFOs.

The Light of the Soul

The concept of the human soul possessing a light-filled core is common to folk traditions. Spirit beings or gods and goddesses of light play a central role for many cultures, if not all. Miniature spirit beings known as ‘the little people’ were regarded as stars and beings of light.4 An example are the light-elves, the liós-álfar of the Nordic mythology who personify the light, and who resemble Tolkien’s bright and positive elves in The Lord of the Rings.

In European philosophy, Plato described the soul as auge, splendour, brilliance, and radiance. The Neo-Platonists used the term augoeides, meaning possessed of a form of auge: in other words, brilliant light is the prime essence of the spirit-body and of all bodies. The Neo-Platonist, and later Christian, philosopher John Philoponus speak of a ‘bright rational soul’ in distinction to a passionate soul that is vulnerable to attack by demons. Cicero knows of a lumen naturae, a natural inner light, while according to Plutarch the souls of the dead can sometimes appear in a shell of flames – some in clear light, others seeming impure or stained.

Paracelsus coined the term Sternenleib, astral body, meaning a radiating body of light, which remains popular. Today the most widespread symbol of the soul is the candle of life, that burns as long as a person lives. This motif is found in fairy tales such as the Grimm brothers' Gevatter Tod (Godfather Death).5 In folklore traditions, a small flame seen shining above a house indicates the dying process of an occupant, called corps candles in Wales and feg ljus in Sweden.6

Practiced meditators in various traditions often report seeing an unusually bright light accompanied by a deep feeling of inner harmony and fulfilment – in rare cases leading to the experience of enlightenment. The experience of an unusually bright light was often reported by Christian mystics. In Western cultures ‘seeking the light’ has become synonymous among religious and spiritual people with the effort to achieve personal ‘enlightenment’, that is, the search for development and inner growth.

Inner Light: Jacques Lusseyran

The French-American Jacques Lusseyran (1924-1971), a literature professor at Case Western Reserve University, USA, was blinded by an accident at the age of eight. However, he subsequently developed an ability to sense ‘inner light’ in other people. During World War II he used this in the context of underground resistance against the German occupation, in a group which he organized at the age of 17, assessing the character and honesty of individuals who wished to join. This inner perception was always correct. In one case, a medical student did not radiate any light, Lusseyran perceived merely a ‘black bar’ between himself and the volunteer. The student had been highly recommended and was accepted anyway, but turned out to be a traitor, which led to the demise of the group and for Lusseyran one year’s incarceration in Buchenwald concentration camp. In his biography And There was Light Lusseyran explains the role played by the inner light in his life:

I was aware of a radiance emanating from a place I knew nothing about, a place which might as well have been outside me as within. But radiance was there, or, to put it more precisely, light. It was a fact, for light was there…

I saw light and went on seeing it though I was blind… The amazing thing was that this was not magic for me at all, but reality… I was not light myself, I knew that, but I bathed in it as an element which blindness had suddenly brought much closer. I could feel light rising, spreading, resting on objects, giving them form, then leaving them… As I remember it, there were no longer the same differences between things lit brightly, less brightly, or not at all. I saw the whole world in light, existing through it and because of it... Light threw its colour on things and on people. My father and mother, the people I met or ran into in the street, all had their characteristic colour which I had never seen before I went blind… the colours were only a game, while light was my whole reason for living. I let it rise in me like water in a well, and I rejoiced.7

Healing

Of immense importance for percipients are experiences in which they receive healing. This is found notably in the encounter with the light in NDEs, but it occurs also in other contexts.  For example Elisabeth Lannge, a Swedish financial adviser who is also a medium, experienced the healing power of the light while still in full control of her body and brain. She reported:

Some years ago one half of my face was paralyzed due to an infection of the large facial nerve…  It was an extremely painful illness…  One evening the pain was unusually acute… I had taken two Alvedon and one Voltaren tablets. I didn’t want any stronger medication, such as morphine… I wanted to have full control over my body and brain… Suddenly the room was lit up by shining light, something I had never seen before. Light of a calibre that I thought quite simply didn’t exist. I looked around me surprised, and noticed every detail in the room. I believed it was the light one sees when one dies. I believed, in other words, I was going to die of pain. At that moment the radio program I had been listening to, finished. I don’t remember anything after that. That night was the first night I slept soundly since my illness. Those who have experienced pain know that you wake up several times during the night, but that night I slept. When I finally woke up, I realised it wasn’t so late, and I felt strange without understanding quite what I was feeling. I didn’t understand then that I was no longer feeling any pain. I went to the bathroom and tried to avoid seeing my image in the mirror, as a partially paralyzed face is not something one wishes to see. But for whatever reason I glanced in the mirror and - to my surprise - saw a face fully recovered.

Later on during the day my daughter rang and asked how I was feeling. I told her what had happened and discovered that, at exactly the same moment I had seen the beam of light in my room, my daughter together with her friends had sent distant healing to me. Sometime later I found out that another group of people had also sent me distant healing at that point in time. The radio program helped confirm the time. I am personally convinced that ‘something’ occurred during the healing, something positive which made my facial paralysis go away. I can also mention that the neurologist at Karolinska Institute, whom I visited some days later, was surprised the paralysis had gone. It was relatively unusual to see recovery take place so quickly. I challenged him, saying it was presumably due to distant healing. He was not in the least irritated, but answered: ‘One does not know everything’...8

Experiences of extraordinary light phenomena are well known in cultural anthropology, scientific folklore, philosophy, religious studies and psychical research. However, as yet these striking phenomena are not identified as a specific and independent research discipline: the main research occurs in the context of NDEs9 (Kübler-Ross,10 Moody,11 Ring,12 Sabom,13 van Lommel,14 Fenwick and Fenwick,15 Sartori,16 Parnia).17

Of the respondents in a large-scale 1982 Gallop poll, fourteen percent reported a light phenomenon having been a feature of their NDE. Other studies found that between 16 percent18 and 60 percent19 of NDE experiencers reported ‘seeing the light’ while 1020 and 80 percent21 had experienced ‘entering the light.’ Light phenomena are also central to persons who are not only close to death but who in fact soon afterwards die so-called deathbed visions22 and who may exhibit an unusual light visible to loved ones.

Light phenomena are reported by persons undergoing stress, crisis, life changing events, major decisions, and grief - a category named ‘crisis apparitions’.23 So-called ‘after-death communications’ (ADCs) also often include experiences of light relating to the dead.24 These may be interpreted as encounters with angels, a popular topic but as yet not one that has been subjected to serious research (an exception is a study by Emma Heathcote-James).25

Case Collections

Studies have been carried out independently by Mark Fox, an English theologian, and Annekatrin Puhle, a German philosopher. Fox explored the Religious Experience Research Centre (RERC), an archive established by Sir Alister Hardy and now located in Lampeter, Wales, which contains some six thousand descriptions of personal spiritual experiences, many of them involving unusual light phenomena.26 He assembled a case collection of nearly four hundred accounts.

Puhle looked for such reports in the interdisciplinary literature dating back to the founding of the Society for Psychical Research in 1882. In total she analysed 809 case descriptions found mainly in monographs and collective volumes apart from a few journals, plus a further 51 first-hand reports given to her directly as a result of publicity by individuals in Sweden, Germany, Austria, Switzerland and Iceland. She included for example collections by Fox (153 cases),27 Fenwick and Fenwick (77),28 Guggenheim and Guggenheim (71),29 Reilly (43),30 Gurney, Myers and Podmore (36),31 Rankin (31),32 Bailey and Yates (27),33 and Arcangel (20).34

Despite their size, these case collections cannot be considered to be fully representative. However, they do offer an initial insight into the variety and commonality of those experiences, constituting a sizable sample of the extant literature as well as new experiences being reported. While most were written up by researchers, others fulfil the ideal of being written directly by the experiencer35 or - as often happens with NDEs - by the medical staff involved.36

Another consideration is the time span between the event and the documentation: this can strengthen or weaken the reliability of a case because of the way memory edits past events. This makes the presence of witnesses especially important.

Experiencing Non-Physical Light

A non-physical light can be perceived both with eyes closed - ‘inner’ sight - and eyes open.  Blind individuals too occasionally report experiencing inner light of a bright and seemingly supernatural sort.37

In Puhle’s study, 56% of literature cases that specified gender and 75% of the first-hand reports were reported by females.38 The reasons are unknown but may include a greater receptivity and awareness among women with regard to such experiences, or at least a greater willingness to talk about them.

In most cases no indication was given of the age of the experiencer, so no conclusions about a possible effect of age on the experiences could be reached.  Among the literature reports, 5% concerned children or very young persons, while most of the interviewees were young adults, from around age 20.39 One person reported having a memory of a striking experience during birth.40

State of Mind

Current circumstances and state of mind at the time of the event played a crucial role, although not all case reports revealed such information. Thirty types of situations (including those around death, crisis, illness, accident, suicide attempt) and states of mind could be distinguished: about half of those who gave such information reported being awake during the experience (140 persons = 17%), while the other half were in a sleep-related state (147 persons = 18%) - typically hypnagogic, hypnopompic, or dreaming.41

States of mind during the experience include:

  • wakefulness - seeing with open or closed eyes
  • awake but in an altered state of mind
  • daydream
  • hypnagogic or hypnopompic states
  • dream
  • lucid dream
  • out-of-body experience (OBE)
  • concentration
  • meditation
  • prayer

Witnesses

Like many exceptional experiences, light phenomena are reported to have occurred most often with only one other person present. In Puhle’s study, 88% of the literature cases and 86% of first-hand cases (89 out of 809) were witnessed by more than one person.  In three cases more than 50 people were said to have been present. The reactions of dogs were noticed in two cases.42 In another two cases, photographs claims were made with regard to photographs taken at the time of the event.43

Also worth noting are the mass visions of unusual light occurring during religious experiences, such as the Marian visions in Lourdes and Medjugorge, and the ‘dance of the sun’ in Fatima that was witnessed by 150 people. Lights in the sky thought to be UFOs were widely reported in Hessdalen, Norway, starting in 1981 and continuing intensively for three years; they are still occasionally observed.

Variations of the Light Phenomena

The appearance of the light described in case reports varies greatly. The ‘lightform’ – a term employed by theologian Mark Fox44 – is described as a shapeless light, a ball or a beam of light; as a light around or radiating from inside a person; light shining around a dying person; or the light around the apparition of a deceased person. Some people describe an experience with a ‘being of light’ or, if it occurs in Christian context, with an angel. 

The light can appear in various shapes and forms:

  • non-specific form of light
  • light balls
  • light beams
  • illumination of places
  • special lightforms
  • light that changes into an apparition of a person or being
  • light radiating from or around a dying person
  • light around an apparition of a living or dead person
  • light around a living person: aura, halo, or gloriole
  • light radiating from inside the percipient’s body
  • angels, god, gods, and beings of light.

Numerous, mostly non-scientific books have been published on encounters with angels, which often appear in the midst of bright and blinding light. In a scientific study by Emma Heathcote-James based on 350 personal anecdotes, about percent described the encounter as ‘an experience of light’. Most commonly the experiences were visionary, of an angel seen as a white figure (31%).45

Circumstances of the Experiences

The experience are not bound to any specific condition, and in principle can happen at any moment to anybody in everyday life. However they appear to be linked with certain circumstances, such as:

  • stress
  • crisis
  • danger
  • illness
  • post-organ transplant
  • near-death-experiences (ndes)
  • deathbed visions and apparitions of the dying
  • appearances of the dead
  • funerals and expression of grief
  • inner growth/meditation
  • mystical experiences/enlightenment

Major Features

Mark Fox analysed 356 accounts of encounters with the light and identified eight major categories:46

  1. unusual lights with multiple witnesses (10 cases)
  2. solitary experiences of unusual light (86)
  3. unusual lights that wrap and fill (77)
  4. illuminations of landscapes and people (35)
  5. lights seen during near-death experiences (48)
  6. visionary encounters with light (80)
  7. beams, rays, shafts (13)
  8. flashes of light (7)

For Fox, three types in particular constitute what he calls the ‘core’ experience: those that occur at times of crisis; those that create positive feelings; and those that are followed by positive results.

A further distinction concerns the colour of the light, which, although not specified in each account, was most often reported: a golden light (31 accounts), followed by white light (28), and blue light (10). In only two or three cases were several colours of light seen.47

Remarkable recurring features of light phenomena experienced during NDEs are described in The Truth in the Light by Peter and Elizabeth Fenwick:48

  • intensity of light
  • wish to enter the light
  • almost touching the light
  • feeling of warmth
  • feeling of an embrace or being surrounded by light
  • feeling of love, joy, peace, serenity, beauty, and good
  • losing one’s fear of death
  • feeling of a wonderful experience, of bliss
  • ineffable experience

In her study, Puhle identified twelve major features:49  

  1. encounter with a shapeless light or any lightform other than human
  2. encounter with a dying human being in light
  3. encounter with a deceased human being in light
  4. encounter with an unknown human being in light
  5. encounter with a being of light, a religious being like an angel, or god
  6. communication with the light or light figure
  7. the meaning of the experiences
  8. message or information
  9. advice for, or foretelling of, the future
  10. comfort and wellbeing derived from the light or the light figure
  11. influence and impact and/or transformation of the experiencer
  12. confidence in life after death

ESP and Afterlife

Non-verbal communication could imply a telepathic exchange of content, as could the communication of veridical information inaccessible at the time in any other way. Precognition is implied if the experience gives information about a future event that later takes place in reality.

Seven percent of percipients said the event changed their attitude to death, convincing them of a continuation of the soul or consciousness after death.50  The true number could be higher, given that the percipients were not specifically asked about this.

Meaning and Transformation

The most remarkable feature is the deep impression of the encounter with an exceptional light and the meaningfulness of this for the percipient, reported by 91% of percipients in Puhle’s study. More than half (57%) characterize their feelings in the light as wellbeing, warmth and love, and of being protected and safe. Nearly half (42%) said the experience was life transforming.51

In almost all cases the encounter with a spirit light left a lasting positive impression. In Puhle’s collection, this was the case for nearly half the percipients (42%)52 for whom the experience radically changed their views on life.53

Fox states that

in over half the cases, the lights occurred at a time of crisis; they represent a turning point in the crisis or in the life of the witness; in almost every case they are associated with positive feelings; the experiences often lead to the transformation of witnesses.’54

The weight of the impact of an encounter with the light naturally is…

very individual, as personal development and sudden changes in life are dependent on the level each individual lives and what s/he recognizes as an advancement in his or her life.’55

The light experience can support inner growth and raise the level of conscious life up to the profound experience of a connectedness with some greater consciousness, just as described in Maurice Bucke’s classic work Cosmic Consciousness.56

Annekatrin Puhle

Literature

Alexander, E. (2012). Proof of Heaven: A Neurosurgeon’s Journey into the Afterlife. New York: Simon & Schuster.

Arcangel, D. (2005). Afterlife Encounters: Ordinary People. Extraordinary Experiences: Charlottesville: Hampton Road Publishing Company.

Bailey & Yates (1996). The Near-Death Experience: A Reader. New York & London: Routledge.

Barrett, W. (1926 / 1986). Death-Bed Visions: The Psychical Experiences of the Dying. 1st edition London: Methuen, 1926. Wellingborough: Aquarian Press, 1986.

Bucke, R.M. (1901). Cosmic Consciousness: A Study in the Evolution of the Human Mind. Philadelphia: Innes & Sons.

Dalzell, G. (2002). Messages: Evidence for Life After Death. Charlottesville, VA: Hampton         Roads Publishing Company, Inc.

Devereux, P. (1982). Earthlights. London: Turnstone.

Elsässer-Valarino, E. (1995). Erfahrungen an der Schwelle des Todes. Was erlebt ein sterbender Mensch? Wissenschaftler untersuchen das Nahtod-Phänomen. Kreuzlingen: Seehamer Verlag.

Fenwick, P. & Fenwick, E. (1995 / 1996). The Truth in the Light: An Investigation of over 300 Near-Death Experiences. London: Hodder Headline. Soft cover edition 1996.

Fenwick, P. & Fenwick, E. (2008). The Art of Dying. London: Continuum.

Finucane, R.C. (1984). Appearances of the Dead: A Cultural History of Ghosts. Amherst, New York: Prometheus Books.

Fox, M. (2008). Spiritual Encounters With Unusual Light Phenomena: Lightforms. Cardiff: The University of Wales.

Green, T. & Friedman, P. (1983). ‘Near-Death Experiences in a Southern California Population.’ The Journal of Near-Death Studies, 3, 77-96.

Grip, G. (1994). Allting Finns. Stockholm: Bokfoerlaget Forum. ISBN 91-37-10580-9.

Guggenheim, W. & Guggenheim, J. (1995). Hello from Heaven. Longwood, Florida, USA: The ADC Project, PO Box 916070, Longwood, Florida 32791-6070, USA.

Gurney, E. Myers, F. & Podmore, F. (1886). Phantasms of the Living. 2 Volumes, London: Truebner & Co.

Haraldsson, E. (2012). The Departed Among the Living: An Investigative Study of Afterlife Encounters. Guildford, UK: White Crow Books.

Heathcote-James, E. (2002). Seeing Angels: True Contemporary Accounts of Hundreds of Angelic Experiences. London: John Blake Publishing.

Holden, J.M., Greyson, B. & James, D. (2009). The Handbook of Near-Death Experiences: Thirty Years of Investigation. Foreword by Kenneth Ring. Santa Barbara, California: ABC Clio.

Hyltén-Cavallius, G.O. & Stephens, G. (1848, 1978). Schwedische Volkssagen und Märchen. Wien: Carl Haas’sche Buchhandlung, 1848; New print Leipzig: Zentralantiquariat der DDR, 1978.

Kellehear, A. (2009). ‘Census of non-western near-death experiences to 2005: Observations and critical reflections.’ In

Holden, J.M., Greyson, B. & James, D. (eds.) The Handbook of Near-Death Experiences. Santa Barbara: Praeger/ABC-CLIO.

Kübler-Ross, E. (1969). On Death and Dying. New York: MacMillan.

Moody, R.A. (1975). Life after Life. 1st edition, Covington, GA: Mockingbirds books.

Osis, K. & Haraldsson, E. (1997). At the Hour of Death. New York: Avon.

Lommel, P. van (2007/2010). Consciousness Beyond Life: The Science of the Near-Death Experience. Original Dutch version 2007; 1st American edition New YorK. Harper Collins, 2010.

Lusseyran, J. (1953/2007). And There Was Light. Gateshead, UK: Athenaeum Press. Original French edition 1953.

Parnia, S., with Young, J. (2013): Erasing Death: The Science That Is Rewriting the Boundaries Between Life and Death. New York: Harper Collins.

Pasricha (2008). ‘Near-Death Experiences in India. Prevalence and New Features.’ Journal of Near-Death Studies, 26 (4), 267-282.

Puhle, Annekatrin (2010). Zwerge: Begegnungen und Erlebnisse mit dem Kleinen Volk. Foreword by Marita Lück, Afterword by Ebbe Schö̈n. Grafing: Aquamarin.

Puhle, A. (2013). Light Changes. Experiences in the Presence of Transforming Light. Foreword by Peter Fenwick, afterword by Barbara Bunce. Guildford, UK: White Crow Books.

Puhle, A. (2016). Licht ins Jenseits. Ein Studie über Erfahrungen mit ungewöhnlichem Licht. In Sei Wie Du Willt Namenloses Jenseits by C.A. Tuczay et al (Eds.), Vienna: Praesens.

Rankin, M. (2008). An Introduction to Religious & Spiritual Experience. London: Continuum International Publishing Group.

Reilly, C. (2005). Walking with Angels: Inspirational Stories of Heavenly Encounters. London: Constable & Robinson Ltd.

Ring, K. (1980). Life at Death: A Scientific Investigation of the Near-Death Experience. New York: Coward, McCann and Geoghegan. 1980.

Ritchie, G. & Sherrill, E. (1978). Return from Tomorrow. Old Tappan, NJ: F.H. Revell.

Sabom, M. (1982). Recollections of Death: A Medical Investigation. New York, NY: Harper and Row.

Sabom, M. (1998). Light & Death: One Doctor’s Fascinating Account of Near-Death Experience. Grand Rapids, MI: Zondervan.

Sartori, P. (2005). A Prospective Study to Investigate the Incidence and Phenomenology of           Near-Death Experiences in a Welsh Intensive Therapy Unit. PhD thesis. University of Wales, Lampeter.

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Winkler, E. (1996). Das Abendländische Totenbuch: Der Tag an dem Elias starb. Hamburg: Corona.

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References

  • 1. Goethe, from the Poem ‘Zahme Xenien III’, 1820-1826.
  • 2. Fox, 2008, 34-44.
  • 3. Devereux, 1982.
  • 4. See the chapter ‘Licht aus dem Dunkel der Erde: Zwerge als Sterne und Lichtwesen’ (light from the darkness of the earth: Dwarfs as stars and beings of light) in Puhle, 2010, chapter II.4, 119-124.
  • 5. Grimm, Kinder- und Hausmärchen (KHM) 44.
  • 6. Hyltén-Cavallius & Stephens, 1978.
  • 7. Lusseyran, 2007, 10-11.
  • 8. First-hand account by Elisabeth Lannge, 26th of November 2009, reported to Annekatrin Puhle, quoted from Puhle, 2013, 123-124.
  • 9. Holden et al, 2009.
  • 10. Kübler-Ross, E. (1969).
  • 11. Moody, R.A. (1975).
  • 12. Ring, (1980).
  • 13. Sabom, (1982).
  • 14. Lommel, (2007/2010).
  • 15. Fenwick & Fenwick, (1995/1996).
  • 16. Sartori, (2005).
  • 17. Parnia, (2013).
  • 18. Ring, (1980).
  • 19. Green & Friedman, 1983.
  • 20. Ring, 1908.
  • 21. Green & Friedman, 1983.
  • 22. Barrett, 1926 / 1986; Osis & Haraldsson, 1997.
  • 23. Kellehear, 2009, 135–158.
  • 24. 81 cases in Guggenheim & Guggenheim, 1995; 15 cases in Haraldsson, 2012; see also Finucane, 1984.
  • 25. Heathcote-James, 2002.
  • 26. Fox, 2008; Puhle, 2013; Puhle, 2016.
  • 27. Fox, 2008.
  • 28. Fenwick & Fenwick, 1995 / 1996.
  • 29. Guggenheim & Guggenheim, 1995.
  • 30. Reilly, 2005.
  • 31. Gurney, Myers & Podmore, 1886.
  • 32. Rankin, 2008.
  • 33. Bailey & Yates, 1996.
  • 34. Archangel, 2005. See for the all sources Puhle, 2013, 23-24.
  • 35. Ritchie, 1978; Grip, 1994; Dalzell, 2002; Lusseyran, 1953 / 2007; Alexander, 2012.
  • 36. Kübler-Ross, 1969; Moody, 1975; Fenwick & Fenwick, 1995 / 1996; Lommel, 2007; Parnia, 2013.
  • 37. Puhle, 2013, 191, case 807; Heathcote-James, 2002, 93-110.
  • 38. Puhle, 2016, 348.
  • 39. Ibid.
  • 40. Grip, 1994.
  • 41. Puhle, 2013, 212-213, table 9.
  • 42. Puhle, 2016, 349.
  • 43. Puhle, 2013, cases 784 and 766.
  • 44. Fox, 2008.
  • 45. Heathcote-James, 2002, 32-33.
  • 46. Fox, 2008, 37-166, 169.
  • 47. Fox, 2008, 170-171.
  • 48. Fenwick & Fenwick, 1996, 167.
  • 49. Puhle, 2013, 198-200; Puhle, 2016, 343-346.
  • 50. Puhle, 2013, 203.
  • 51. Puhle, 2013, 205-206, table 3.
  • 52. Puhle, 2013, 205-206, table 3.
  • 53. Puhle, 2013, 219.
  • 54. Mark Fox, personal communication with Annekatrin Puhle.
  • 55. Puhle, 2013, 200.
  • 56. Bucke, 1901.