Earlier witness statements heard in the inquest told of how Mr Erbay groaned when he was approached as he lay down at the reserve known as Duck Pond.
But pathologist Dr Jane Vuletic was "60 to 80 per cent" certain that he had been hurt in a fall.
"Normally you see injuries from a road surface on the limbs which I didn't see but I could not completely rule it out.
"But I didn't figure it as a possibility that he could have been struck like that ... I didn't find any evidence to support it."
Mr Erbay's death was caused by his chest injury in association with his heart condition - hypertrophic cardiomyopathy - which causes the heart muscle to become thick, making it harder for it to work efficiently.
He had suffered multiple abrasions to most of his left side that Dr Vuletic said could have come from a number of falls or scrapes against the rough undergrowth in the plantation.
He also had four broken ribs and a punctured lung.
Detective Sergeant Martin Hughes of Thames later said it was possible Mr Erbay could have been injured by falling on rocks in the Rings Beach area.
"Obviously it would be nice to know where his injuries occurred but we can't establish that fact," he said.
Police at first treated his death as suspicious because of the injury to his left eye and the fact that some of his personal items were missing.
But the inquiry was downgraded to a sudden death.
"If I thought there was anything untoward we would still be out there looking," he said.
An autopsy on January 5 revealed small traces of alcohol and cannabis in his body but there were no signs of the Ecstasy his friends claimed he said he had taken at the Whitianga party on New Year's Eve.
The inquest had heard that Mr Erbay had been at a party in Whitianga and was walking with his mate Wilhelm Killip to his friends' parents' home when the pair separated at the south end of Wharekaho Beach around 4am.
Having walked barefoot for more than 20km - sometimes on gravel roads and rocky crops at beaches - Mr Erbay is understood to have reached Matarangi around 9am.
He asked holidaymakers for directions to Wharekaho and bought drinks and biscuits at the local store.
The inquest will hear from one further witness, Mr Erbay's psychologist, who will present his evidence in Auckland on December 14.
WITNESS APPEAL
The family of Cem Erbay are appealing to anyone who was in the Rings Beach area between 8.30am and 9am on January 1 and saw Mr Erbay to contact Hamilton police on 07 858 6200.