In In Re Application of Winchester (1991), 44 Ill. Ct. Cl. 232, the Court found that firefighters were encouraged to take part in physical activity since it helps maintain the physical conditioning necessary in that line of work. Firefighter Winchester was on duty at the time of his fatal accident. While waiting for instruction, he became involved in a scrub football game. While attempting to catch a pass, he lost his footing, fell and struck his head on the concrete resulting in his death. The Court made an award pursuant to the Law Enforcement Officers and Firemen Compensation Act.