As stated in Point 13, the hypothesis of the necessary and suf®- cient conditions rests on the presence of all of them. Even so, it is not uncommon to read that `congruence takes precedence' (for example, Rogers interviewed by Hobbs 1989: 21) or that unconditional positive regard (UPR) is the curative condition (for example, Bozarth 1998: 83) or descriptions as to how empathy cures (for example, Warner 1996: 127±143) or that it is the communication or perception of empathy and/or UPR that makes for constructive personality change (for example, Wilkins 2000: 33±34). However, in some ways such statements are unhelpful or even misleading ± certainly they seem open to misinterpretation. It is clear from Rogers' original formulation that no one condition is more important than the other. So how and why have people come to make statements that appear to contradict this?