At speed, maybe.
It proves nothing, but my wife and I, and 2 children, were in a Ford Orion that was rear ended in 1987/8. The roof was bent and the back doors wouldn't close, so it was not a trivial bump. No whiplash.
The same wife ran into a car at a roundabout (same accident as tyro) in 2014. GPS speed was 10mph (from the dashcam). The Popemobile need a new bumper, bonnet, lights, grille, wing etc. No whiplash.
430,000 cases? It's virtually all fraud.
In the 70s and 80s head restraints were far from universal. I don't recall anybody getting whiplash. Dead maybe, but no whiplash!
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