In the past decade, hypermedia programmes have gained attraction for the purposes of teaching and learning. These programmes provide students with freedom of navigation. On the other hand, students are required to develop learning paths by themselves. Empirical evidence indicates that not all of learners can benefit from hypermedia learning. In particular, they have problems to deal with non-linear learning. Research into individual differences suggests cognitive styles have significant effects on student learning in hypermedia programmes. In this study, a cognitive model is presented to illustrate how students with different cognitive styles react to non-linear learning within hypermedia programmes by analysing the findings of previous studies. Implications for the design of adaptive hypermedia learning programmes are also discussed.