(dissenting). The opinion announced by the majority today correctly focuses on the general issue before us: whether the commissioner properly concluded that the plaintiff’s injury was one not “arising out of and in the course of his employment” within the meaning of the Workmen’s Compensation Act. In holding that the commissioner erred in reaching this conclusion, the majority has formulated a “new and expanded test for *557oases like the present one.” I believe the “new and expanded test” which the majority has adopted in defining “incidental to employment” is an overly broad one, will be difficult to apply either uniformly or realistically and is not warranted by the record in the present case. For those and the following reasons, I am thus compelled to dissent.
As the majority points out, the crucial question is whether the plaintiff was doing something “incidental to his employment” when the accident happened, since the plaintiff concedes, as he must, that he was not injured in the performance of his duties. In considering whether an activity is incidental to employment, we said in Smith v. Seamless Rubber Co., 111 Conn. 365, 368-69, 150 A. 110 (1930): “Where an employer merely permits an employee to perform a particular act, without direction or compulsion of any kind, the purpose and nature- of the act becomes of great, often controlling significance in determining whether an injury suffered while performing it is compensable. If the act is one for the benefit of the employer or for the mutual benefit of both, an injury arising out of it will usually be compensable; on the other hand, if the act being performed is for the exclusive benefit of the employee so that it is a personal privilege or is one which the employer permits the employee to undertake for the benefit of some other person or for some cause apart from his own interests, an injury arising out of it will not be compensable.” The commissioner was correct in determining as a matter of fact that no benefit accrued to the employer from the ping-pong playing. The commissioner found, and the plaintiff does not contest, that playing ping-pong had no effect on work habits or work regulations. Especially in light of those find*558ings, the fact that a superintendent played from time to time and that emergency work assignments were occasionally handed out to the “earlybirds” do not compel a conclusion that the employer materially benefited. See Williams v. State, 152 Conn. 692, 694, 211 A.2d 700 (1965); Mulligan v. Oakes, 128 Conn. 488, 492, 23 A.2d 870 (1942). The commissioner’s conclusion was not so unreasonable or illogical as to justify judicial interference. Rivera v. Guida’s Dairy, 167 Conn. 524, 525, 356 A.2d 184 (1975); Labbe v. American Brass Co., 132 Conn. 606, 609, 46 A.2d 339 (1946).
The fundamental issue in any case of this nature is whether there is a sufficient connection between the employment and the recreational activity for the activity to be regarded as an incident of the employment. In searching for a work relation, compensation commissioners and courts in this and other states have paid increasing attention to two related factors in addition to benefit to the employer. The first of these is the extent of employer involvement in the activity; the second is the extent to which the activity in question is customarily engaged in by the employee. See Davis, “Workmen’s Compensation in Connecticut — The Necessary Work Connection,” 7 Conn. L. Rev. 199, 212-13 (1973-1974); 1A Larson, Workmen’s Compensation Law §§22.20 — 22.24 (1978). I do not believe, however, that either of these factors are present sufficiently in this case to establish a connection between the employment and the ping-pong playing which could make that activity “incidental to the employment.”
The spectrum of employer involvement in employees’ recreational and social activities can range from compulsion, to sponsorship and encourage*559ment, to mere permission or toleration. This is not a case, however, where an employer expressly or impliedly required a certain activity as part of the job, bringing that activity within the course of employment. See Stakonis v. United Advertising Corporation, 110 Conn. 384, 148 A. 334 (1929) (an employee ordered by his foreman to attend an annual company picnic or lose a day’s pay was awarded compensation when injured on the way to the event). In factual situations less extreme the problem becomes more difficult and commissioners and courts must very closely examine the degree and form of employer involvement to determine whether the employer has recognized or should recognize a work connection. Employer involvement was found to be minimal in the present case. Management gave a few of the men permission to install and use a ping-pong table in a comer of the garage at their own expense, and prescribed off-work periods for play. A superintendent occasionally joined in the game. The employer did nothing further to regulate or encourage play, financially or otherwise. This is a far cry from the “company team” cases in which compensation has been awarded for injuries sustained in league baseball games on the basis of substantial employer involvement as manifested by acts of encouragement or financial subsidy. See the cases reviewed in 1A Larson, supra % 22.24. The commissioner’s memorandum of opinion indicates that he took the employer’s limited role in the recreational enterprise into account in concluding that ping-pong playing was not incidental to the plaintiff’s job.
Neither can I agree that the customary nature of the recreational activity on the employer’s premises prior to and during the work day should be *560the linchpin of compensability. Although custom is an important consideration in a recreational injury case and in other types of cases, we have recognized the significance of whether a particular activity on the premises is a habit among the employees; see Mann v. Glastonbury Knitting Co., 90 Conn. 116, 96 A. 368 (1916); there appears to be no good reason in law or logic to adopt a rule to the effect that the customary nature of a recreational activity on an employer’s premises establishes a sufficient work connection as a matter of law, even where employer involvement and benefit are de minimis. Each ease of this nature has its own set of circumstances and each requires its own solution.
Numerous on-the-premises recreational injury cases are reviewed in 1A Larson, supra § 22.10; with the possible exceptions of Nichols v. Workmen’s Compensation Appeals Board, 269 Cal. App. 2d 598, 75 Cal. Rptr. 226 (1969); Mack Trucks, Inc. v. Miller, 23 Md. App. 271, 326 A.2d 186 (1974); and City of Oklahoma City v. Alvarado, 507 P.2d 535 (Okla. 1973), in no case was the mere customary nature of the activity found sufficient, without more, to justify awarding compensation. See Winter v. Industrial Accident Commission, 129 Cal. App. 2d 174, 276 P.2d 689 (1954) (caddy injured on day off while playing golf on employer’s course); Conklin v. Kansas City Public Service Co., 226 Mo. App. 309, 41 S.W.2d 608 (1931) (baseball encouraged by employer); Geary v. Anaconda Copper Mining Co., 120 Mont. 485,188 P.2d 185 (1947) (handball injury; employees on call during lunch hour); Uzendoski v. City of Fullerton, 177 Neb. 779, 131 N.W.2d 193 (1964) (lifeguard injured diving into employer’s pool while on duty); Tocci v. Tessler & Weiss, Inc., 28 N.J. 582,147 A.2d 783 (1959) (employer supplied *561softball equipment); Brown v. United Services for Air, Inc., 298 N.Y. 901, 84 N.E.2d 810 (1949) (volleyball encouraged by employer); Dowen v. Saratoga Springs Commission, 267 App. Div. 928, 46 N.Y.S.2d 822 (1944) (employee injured using swimming pool maintained for employer’s resort business); Henry v. Lit Bros., 193 Pa. Super. 543, 165 A.2d 406 (1960) (touch football injury; employees encouraged to devote lunch period to activities on employer’s premises); Kingsport Silk Mills v. Cox, 161 Tenn. 470, 33 S.W.2d 90 (1930) (basketball encouraged by employer); Salt Lake City v. Industrial Commission, 104 Utah 436, 140 P.2d 644 (1943) (fireman required to take exercise while on 24-hour duty and encouraged to play handball).
Moreover, I am not convinced, as the majority seems to be, that the “custom” test is but a logical extension of the rationale supporting compensation in the “personal comfort” and “horseplay” cases. While analogous, those cases are not controlling. In the personal comfort eases we have held that employee attention to personal needs during the work day is incidental to employment. See Puffin v. General Electric Co., 132 Conn. 279, 43 A.2d 746 (1945), and Lovallo v. American Brass Co., 112 Conn. 635, 153 A. 783 (1931) (employees compensated for injuries received while taking a permitted smoking break). The rationale for the rule is that routine acts of comfort and convenience, such as taking a drink of water, are reasonably necessary for the health and comfort of an employee, are indirectly conducive to the purpose of the employment, and generally do not interrupt the course of employment. Lovallo v. American Brass Co., supra, 639; see Davis, “Workmen’s Compensation,” supra. *562Playing ping-pong is simply not in the same category of ordinary personal needs, such as washing one’s hands, taking a smoking break, or eating lunch.
'In the horseplay cases, we have said that employees may be entitled to compensation for injuries sustained in a customary form of horseplay during working hours that was tolerated by the employer. Shedlock v. Cudahy Packing Co., 134 Conn. 672, 676-77, 60 A.2d 514 (1948); Stulginski v. Waterbury Rolling Mills Co., 124 Conn. 355, 360-61, 199 A. 653 (1938). As explained by Cardozo, J., in the leading case of Leonbruno v. Champlain Silk Mills, 229 N.Y. 470, 472, 128 N.E. 711 (1920), the underlying principle is that it is a natural human tendency to indulge in occasional skylarking with one’s fellow workers. The risks of such physical associations and conditions are risks of the employment. I do not consider playing ping-pong to be in the same category of inevitable horseplay as a shove, a trip, or a punch on the arm.
The majority is of the view that it is anomalous that employee injuries in the personal comfort and horseplay cases may be the subject of compensation, but not the samé injuries arising from the planned recreational activities of the employee, and concludes that “[t]he obvious difficulty in drawing such distinctions or weighing such intangibles [employer benefits] is sufficient reason to adopt a new rule which will avoid arbitrary and unjust results.” I cannot agree that the denial of compensation in this ease is arbitrary and unjust. The commissioner’s finding and memorandum of opinion indicate that he found the lack of employer benefit and involvement fatal to the plaintiff’s claim, notwithstanding the customary nature of ping-pong playing *563on the premises. I adhere to my original view that this is not a case that lies so clearly on the other side of the line that we can say he was wrong. See Woodley v. Rossi, 152 Conn. 1, 6, 202 A.2d 136 (1964); Herbst v. Hat Corporation of America, 130 Conn. 1, 7, 31 A.2d 329 (1943).
I would find no error.