She was admitted to the hospital and when operated a dead foetus was removed. In the case of Frost v Chief Constable of South Yorkshire Police [5], . The term is used to describe psychiatric injury or illness which is caused by the defendant. Once the requirement of proximity of relationship is satisfied, the secondary victims must also establish the facts that he had physical proximity to the accident or its immediate aftermath. Recovery, on the other hand, for a secondary victim is differentiated and is much more restricted. If so, the question arose whether Robertson and Rough had proximity of relationship or close tie of love and affection with Smith. She suffered serious nervous shock as a result and sued the defendant who was responsible for the accident. Another claimant of this case was Rough, who was forty four years old. Common Law - Evidence Law - Amissibility of Evidence Essays - Use Our Free Law Essays To Help You With Your Law Course Codification of Directors Duties was Unnecessary. It is of paramount importance that the law enforcement Cited Mount Isa Mines Ltd v Pusey 1970 The court considered how progress is made in developing the law of liability for damages for psychiatric injury, saying The field is one in which the common law is still in course of development. The defenadant appealed against the decision of Salmon J. No plagiarism, guaranteed! Tel: 0795 457 9992, or email david@swarb.co.uk, Ultrasun v EUIPO (Ultrasun) (European Trade Mark Order): ECFI 20 Oct 2020, Hackney London Borough Council v Mullen: CA 22 Oct 1996, Frost and Others v Chief Constable of South Yorkshire, White, Frost and others v Chief Constable of South Yorkshire and others, British Airways Plc v British Airline Pilots Association: QBD 23 Jul 2019, Wright v Troy Lucas (A Firm) and Another: QBD 15 Mar 2019, Hayes v Revenue and Customs (Income Tax Loan Interest Relief Disallowed): FTTTx 23 Jun 2020, Ashbolt and Another v Revenue and Customs and Another: Admn 18 Jun 2020, Indian Deluxe Ltd v Revenue and Customs (Income Tax/Corporation Tax : Other): FTTTx 5 Jun 2020, Productivity-Quality Systems Inc v Cybermetrics Corporation and Another: QBD 27 Sep 2019, Thitchener and Another v Vantage Capital Markets Llp: QBD 21 Jun 2019, McCarthy v Revenue and Customs (High Income Child Benefit Charge Penalty): FTTTx 8 Apr 2020, HU206722018 and HU196862018: AIT 17 Mar 2020, Parker v Chief Constable of the Hampshire Constabulary: CA 25 Jun 1999, Christofi v Barclays Bank Plc: CA 28 Jun 1999, Demite Limited v Protec Health Limited; Dayman and Gilbert: CA 24 Jun 1999, Demirkaya v Secretary of State for Home Department: CA 23 Jun 1999, Aravco Ltd and Others, Regina (on the application of) v Airport Co-Ordination Ltd: CA 23 Jun 1999, Manchester City Council v Ingram: CA 25 Jun 1999, London Underground Limited v Noel: CA 29 Jun 1999, Shanley v Mersey Docks and Harbour Company General Vargos Shipping Inc: CA 28 Jun 1999, Warsame and Warsame v London Borough of Hounslow: CA 25 Jun 1999, Millington v Secretary of State for Environment Transport and Regions v Shrewsbury and Atcham Borough Council: CA 25 Jun 1999, Chilton v Surrey County Council and Foakes (T/A R F Mechanical Services): CA 24 Jun 1999, Oliver v Calderdale Metropolitan Borough Council: CA 23 Jun 1999, Regina v Her Majestys Coroner for Northumberland ex parte Jacobs: CA 22 Jun 1999, Sheriff v Klyne Tugs (Lowestoft) Ltd: CA 24 Jun 1999, Starke and another (Executors of Brown decd) v Inland Revenue Commissioners: CA 23 May 1995, South and District Finance Plc v Barnes Etc: CA 15 May 1995, Gan Insurance Company Limited and Another v Tai Ping Insurance Company Limited: CA 28 May 1999, Thorn EMI Plc v Customs and Excise Commissioners: CA 5 Jun 1995, London Borough of Bromley v Morritt: CA 21 Jun 1999, Kuwait Oil Tanker Company Sak; Sitka Shipping Incorporated v Al Bader;Qabazard; Stafford and H Clarkson and Company Limited; Mccoy; Kuwait Petroleum Corporation and Others: CA 28 May 1999, Worby, Worby and Worby v Rosser: CA 28 May 1999, Bajwa v British Airways plc; Whitehouse v Smith; Wilson v Mid Glamorgan Council and Sheppard: CA 28 May 1999. In this case, the court considered chronic fatigue syndrome to be a recognizable psychiatric injury[9]. For a secondary victim to be successful in their claim, they must prove the following: It must be reasonably foreseeable that a person of "normal fortitude" might suffer . Again, in the case of Fenn v City of Peterborough[64], the claimant arived home couple of minutes after a gas explosion in which he lost his three children. Employment > Health and safety; The defendants admitted their negligence but also argued that the nervous shock suffered by the mother was too remote. During this period in society there was a view that people of strong moral character did not succumb to their emotions. The function of the defendants was to maintain and operate the bridge. 12 0 obj That appears to be the course advocated by Mullany and Handford, Tort Liability for Psychiatric Damage. [71] As per Cumming Bruce LJ. Note White was known as Frost v. Chief Constable of South Yorkshire Police in the Court of Appeal] LORD GOFF My Lords, These appeals arise from further proceedings following the tragic events which occurred at the Hillsborough Football Stadium in Sheffield on 15 April 1989, when 95 spectators died and hundreds more were injured, one fatally, as . This was a test case . Any opinions, findings, conclusions, or recommendations expressed in this material are those of the authors and do not reflect the views of LawTeacher.net. No issues of. Capacity plays a vital role in determining whether a person can exercise autonomy in making choices in all aspects of life, from simple decisions to far-reaching decisions such as Our academic writing and marking services can help you! .Cited Zurich Insurance Plc UK Branch v International Energy Group Ltd SC 20-May-2015 A claim had been made for mesothelioma following exposure to asbestos, but the claim arose in Guernsey. (now Lord Justice Waller) and the majority in the Court of Appeal erred in reversing him: Frost v. Chief Constable of South Yorkshire Police [1997] 3 W.L.R. The House of Lords, although divided in as to their reasoning, delivered a judgment in favour of the plaintiff. Marital or parental relationship between plaintiff and . The court further considered the issue if both the claimants suffered nervous shock as a result of witnessing the accident. The plaintiffs sought damages for nervous shock. Both cars suffered considerable damage but the drivers escaped physical injury. Frost v Chief Constable of South Yorkshire Police [1997] 3 WLR 1194. The law has imposed lots of requirements for the secondary victims before they can successfully make a psychiatric injury claim. Any opinions, findings, conclusions, or recommendations expressed in this dissertation are those of the authors and do not necessarily reflect the views of UKDiss.com. [27] As per Lord Keith [1992] 1 AC 310 at page 397. % Different kinds of harm The horrific events of 15 April 1989 at the . Lord Dyson MR felt that damages for psychiatric illness could not be recovered in respect of consequences witnessed months, and . Unless and until there is clear evidence of having the close relationship or a close tie of love with the person (primary victims) who is injured or within the zone of danger, the court will not allow any claims for psychiatric injury brought by the secondary victims. was reluctant to interfere with the findings of the court and agreed with the decision given by McNair J. but the court dismissed their claims for damages, claiming that they did fulfill the criteria of rescuers. According to Stephenson LJ[69], although the claimants psychiatric illness was reasonably forseeable by the defendants and they owed a duty of care to the claimant, but it was policy considerations that hampered the claimant from establishing a claim and recover damages for psychiatric illness. Lord Oliver[30] thought that, Mr. Brians action failed not only because he could not provide with evidence of close tie of love and affection but also because the perception of the shocking event was gradual as opposed to the sudden appreciation by sight or sound of a horrifying event. Mental Health of Adolescent and Young Adult Cancer Survivors. Principle of Frost v Chief Constable of South Yorkshire Police (1998) police officers who were present in the aftermath of the Hillsborough disaster sued for post traumatic stress disorder. The distinction between primary victim and secondary victim was made in the Alcock v Chief Constable of South Yorkshire Police, where all claimants were secondary victims. [66] Michaell A Jones, Liability for Psychiatric Illness More Principle, Less Subtlety? [1995] 4 Web JCLI. This took place while Robertson was driving the van on a carriageway which was high above the water. Therefore the claimants appeal was dismissed by the Court of Appeal. We do not provide advice. The chief constable of South Yorkshire police told junior officers four days after the Hillsborough disaster that Liverpool football club supporters should be blamed for causing the deaths, the . A question arose before the court; whether the mother had suffered nervous shock by her own unaided realization of what she had seen with her eyes or the shock was caused as a result of what she was told by the bystander. Although the boy arrived home eventually but his mother suffered from a nervous shock[45]. As a result of the negligence of the police department, ninety six spectators died in a massive crash and more than approximately four hundred spectators were severely injured in that accident. It was held by the court that (according to the decision of Bourhill case), the defendant owes no liability towards the claimant although there was a liability in relation to the accident of the boy. Lord Morton of Henryton: it has never been the law of England that an invitor, who has negligently but unintentionally injured an invitee, is liable to compensate other persons who . (back to preceding text) I am compelled to say that I am unable to accept this suggestion because in my opinion (1) the proposal is contrary to well-established authority; (2) the proposed control mechanism would erect an artificial barrier against recovery . The married mother-of-one began her policing career in 1998 with Humberside Police and joined South Yorkshire Police in 2017 as Assistant Chief Constable. The claimant was a fire officer who attended the tragic accident being informed in the course of his employment. [45] Cases and Commentary on Tort, by Barbara Harvey & John Marston, 5th Edition. However, the decision in the case of Dooley V Cammen Laird preserved the distinction between primary and secondary victim. However, an action for psychatric injury was brought by the claimant against the defendant and the owners of the garage[57]. In the case of Brice v Brown[4], hysterical personality disorder was considered to be a psychiatric injury. 2 Alcock v Chief Constable of South Yorkshire Police [1992] 1 AC 310. The apparent injustice of this position has been acknowledged . Lists of cited by and citing cases may be incomplete. The House considered claims by police officers who had suffered psychiatric injury after tending the victims of the Hillsborough tragedy. Again this development of the proximity of relationship in this case seems quite unfair to some of the claimants who were seeking compensation as they would not have been aware previously of this .The principle of proximity of time and place was also applied in this case, where a claimant failed to recover. In this case the plaintiff was exposed to asbestos dust. 56 Bourhill v YoungAlcock v Chief Constable of South Yorkshire Police [1943] AC 92. Cited Hinz v Berry CA 1970 Then plaintiff saw her husband killed and her children injured by a runaway motor car. . [25] As per Parker LJ [1991] 3 All ER 88 at 92-94. . In the case of Benson v Lee[62], the claimant was informed that her son had an accident and sustained injuries. The mother came across the tricycle which was lying underneath the taxicab but failed to see the boy. We're here to answer any questions you have about our services. Abstract. [41] Kay Wheat (2003) Proximity and Nervous Shock Common Law World Review 32 4 (313). It was not disputed that D was negligent or, indeed, that this had caused nervous shock to C. The Court of Appeal had previously found in favour of C and D appealed to the House of Lords. The Law Commission Report, Liability for Psychiatric Illnesses, McLaughlin v O Brian (1983) AC 410 310 AT 407. This was a case which involved a huge disaster in the Hillsborough football stadium[23]. The claim was rejected by the House of Lords on the basis that none of the claimants could be considered "primary . Judgement for the case White v Chief Constable of South Yorkshire. . Marc Rich & Co AG v Bishop Rock Marine Co Ltd [1995 . The teenager, who is now fighting for his life, was struck by a blue Mini Cooper at the junction of Leeds Road and Muffit Lane in Heckmondwike. Introduction [29] As per Lord Oliver [1992] 1 AC 310 at page 417. swarb.co.uk is published by David Swarbrick of 10 Halifax Road, Brighouse, West Yorkshire, HD6 2AG. In order to support this argument, the claimant relied on the decision of the case in In re Polemis and Furness, withy & Co. Ltd[47]. Looking for a flexible role? Top Tier Firm Rankings. If it was not reasonably forseeable then the defendant owes no duty of care to the claimant and there is no liability for negligence on the part of defendant. where the rescuer may not have been in physical danger but was awarded damages due to his putting himself in the 'zone of danger', after the event. A rescuer, not himself exposed to physical risk by being involved in a rescue was a secondary victim, and as such not entitled to claim. The House considered claims by police officers who had suffered psychiatric injury after tending the victims of the Hillsborough tragedy. The requirement of immediate aftermath principle was firmly established in the case of Mcloughlin v O Brian[67]. [40] Cases and Commentary on Tort, by Barbara Harvey & John Marston, 5th Edition: Publication date 2004. After ariving to the garage, the claimant was asked by the defendant to repay the garage bills before he get his car released from that garage. Firstly, it fell to be determined whether an employer owed a duty of care to protect their employees from psychiatric injuries they may incur in the course of their employment. No rule of public policy exists that excludes claim for nervous shock . However in relation to claims brought by siblings this close relationship had to be proven by evidence. White (Frost) v Chief Constable of South Yorkshire Police [1999] 2 AC 455 (Hillsborough, police on duty) The Control Mechanisms - Alcock 1. Music background Another appellant, namely Mr. Robert Alcock, was present in the stadium and lost his brother in law but still failed in his action as it was not reasonably foreseeable by the defendants that he would suffer psychiatric illness. In that case it was not reasonably freseeable by the defendant that the claimant was going to suffer from psychiatric illness after witnessing the accident. *You can also browse our support articles here >. When there is a close relationship between two people, it is a general knowledge and reasonably foreseeable that one of them would be suffering from mental disturbance or psychiatric injury when the other person is in real danger of physical injury. However, in this case, their Lordship took the similar opinion that, the issue of proximity of relationship should be decided on a case by case basis. of Ireland (1884) illustrate that even though no physical injury occurred, the plaintiff was clearly in physical danger and therefore was allowed recovery. The winner - given the power to fire the next chief constable - will inevitably prevail on an anti-corruption ticket. Others identified bodies in temporary constructed morgues in the stadium. They claimed that because they were rescuers they should be treated as primary victims. Generally, nervous shock is a term which has been used by lawyers. Hopes had been pinned on the decision of the House of Lords in Frost v Chief Constable of South Yorkshire Police [1998] 3 WLR 1509, but by and large Frost is a disap- pointment. [1981] 1 All ER 809. Is there any liability for self inflicted physical injury which caused the claimants psychiatric illness? In this case, the court was concerned whether the claimants fall into the category of secondary victims and therefore entitled to bring an action against the defendants. School King's College London; Course Title LAW 10999; Uploaded By ColonelHeatKudu28. In the case of Frost v Chief Constable of South Yorkshire Police [1999] Lord Steyn stated that the area of Tort Law relating to psychiatric trauma is rather complex. The outcome of this case would undoubtedly, in my opinion, have set a precedent for future cases relating to nervous shock claims, both in England and Ireland. So, finally, the House of Lord dismissed the appeal made by the claimant. l'LCocI2Vp.0c As a result of experiencing such a dreadful event she subsequently suffered severe nervous shock resulting in the form of psychatric illness. They brought an action against their employer for negligently causing psychiatric illness to them. The Chief Constable of South Yorkshire admitted that a duty of care was owed by his force towards those who died or suffered physical injury as a result of negligent crowd control by . Registered office: Creative Tower, Fujairah, PO Box 4422, UAE. While Robertson was driving the van, Smith was sitting on top of the metal sheet. Lord Wilberforce argued that it was necessary to develop further criteria including strict proximity in time, a close relationship, direct means of communication (personal witness). . The case of Alcock v Chief Constable of South Yorkshire[22]is the best example which provided the criteria for recovery of psychiatric injury claims by the secondary victims. /Filter /LZWDecode In this case, the defendant was claimants son who had a car accident while he was negligently driving his car being drunk. No damages for Psychiatric Harm Alone. .Cited McLoughlin v Jones; McLoughlin v Grovers (a Firm) CA 2002 In deciding whether a duty of care is established the court must go to the battery of tests which the House of Lords has taught us to use, namely: . Since they were not endangered in the discharge of their service or in rescuing, as employees and/or rescuers, the police officers were only secondary victims. Due to the accident, the claimants husband suffered from bruising and the other children suffered from severe physical injuries and shock. He further took the view that, the cases where there is insufficient proximity of relationship must be very carefully considered before allowing the claimants for psychiatric injury claims[20]. White v Chief Constable of South Yorkshire [1998] 3 WLR 1509 House of Lords. miscarriage. A person will be considered as secondary victim if he was present at the scene of the horrifying event and subsequently sustained a psychiatric injury due to witnessing the accident or event in which other person was involved, although he himself was out of the range of foreseeable physical injury[10]. He had known Smith just as a colleague for few years. Only full case reports are accepted in court. In reality there are no refined analytical tools which will enable the courts to draw lines by way of compromise solution in a way that is coherent and morally defensible. Only Parliament could take such a step. [71] The court took the view that, there is no doubt that the psychiatric illness suffered by the claimant was reasonably foreseeable but the existing law on the recovery of damages for psychiatric injury only entitles those claimants to recover damages who had been close or near the accident that caused psychiatric injury as a result of the negligence of the defendants. At common law a distinction is drawn between what is merely the ordinary emotion of grief, anxiety, fear and transient shock which does not constitute sufficient damage and the recognisable psychiatric illness that is established by expert medical evidence. Both cars suffered considerable Damage but the drivers escaped physical injury which caused the claimants suffered nervous shock [ ]... To fire the next Chief Constable of South Yorkshire Police in 2017 as Assistant Chief Constable - will inevitably on. 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