In recent years the biphasic approach initiated by Mow and coworkers, has been very popular in modelling soft, hydrated, cartilage tissues as well as other soft tissues, such as the brain. This work points out that due to the inherent inability of biphasic models in their present form to account for stress-strain rate dependence resulting from the viscoelasticity of the solid phase, the applicability of these models is limited to the loading conditions producing large relative velocities of phases.