It is my understanding that the clubshaft should always remain on-plane when it is swinging through the impact zone (which I will loosely describe as being between the third parallel and fourth parallel) and I am under the impression that this rule applies equally to swingers versus hitters.
The orbit that the clubhead will transcribe during its passage through the impact zone will be circular, and the size of the circular orbit must be related to the angle of the inclined plane - being smaller for a shallower inclined plane (eg. elbow plane), and larger for a steeper inclined plane (turned shoulder plane). The hands will also move inside more quickly if the circular orbit is smaller - eg. Hogan's swing where his clubshaft is slightly below the elbow plane (closer to the hand plane) during its passage through the impact zone - and that it is not dependent on whether a golfer is a swinger or a hitter.
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