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Complicated question! Here’s my thoughts:
Fitness and general health are different things. Fitness can help keep you healthier regardless of weight.
I think someone with a lot of muscle can nudge their way into the overweight BMI category while still being healthy, but I think most people in that situation are serious enough about their sport that they are already using different metrics and measure body composition instead.
Obesity on the other hand, would be incredibly difficult to achieve through muscle mass. Dwayne Johnson is often used as an example, but he is just barely over the line for obesity. And I think most people that use this excuse know that they don’t look like The Rock. There is a lot of science to support that health will deteriorate faster in this category.
Think of BMI like the expiry date on a jug of milk. It doesn’t go bad the exact second it strikes midnight of the expiry date, but you significantly increase your risks the further out you go.