46 patients who had sustained a stroke resulting in paralysis or severe paresis in their upper limb, and a poor prognosis for functional recovery were randomized to undergo an 8-week treatment regimen of either neuromuscular electrical stimulation (NMES) and simultaneous passive range of motion stretches, or a sham treatment. This study was conducted in the sub-acute phase of stroke. Upon completion of the treatment period, results indicated that there was no significant difference in arm passive range of motion, shoulder pain, the ability to perform basic arm activities, the severity of hypertonia/spasticity, arm motor control and subluxation between the experimental and control groups.