A large tower was constructed in the Docklands area of East London which now goes by the name of One Canada Square Capacity and Medical Consent. Page, was involved in a minor car accident, and was physically unhurt in the collision. There was a fear that it would be difficult for the courts to distinguish between a genuine claim and a fictitious claim, and also the fear that if one person recovered, this would in turn lead to a possible floodgate of claims. 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. Finally, the secondary victim is required to satisfy the court that his psychiatric illness was a direct result of witnessing or hearing of the traumatic event or its immediate aftermath[26]. Packenham v Irish Ferries . However, the decision in the case of Dooley V Cammen Laird preserved the distinction between primary and secondary victim. Rough was also driving another van from a few feet behind the Robersons van. [14] Secondary Victims and Nervous Shock by M Dunne (2000) BR 383. [1] Nicolas N (2002), A Remedy for Nervous Shock or Psychiatric Harm- Who Pays?-Volume 9, Number 4. [41] Kay Wheat (2003) Proximity and Nervous Shock Common Law World Review 32 4 (313). Sometimes, the policy consideration came on the way of the secondary victims as an obstacle which did not let the courts give decisions in their favour. The case of White and Others v Chief Constable of South Yorkshire (1998) QB 254 elicited need for necessary distinctions between physical injury and nervous shock and has had an impact on nervous shock claims by bringing other policy considerations into play, for example the Criminal Injuries Compensation Scheme and the Criminal Justice Act of . It was held by Salmon J. [71] As per Cumming Bruce LJ. 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. According to the facts and circumstances of the present case, the clamant was not close to the place of the accident who was informed by someone of that after two hours. He was seriously injured. We do not provide advice. 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 . Three were on duty at the ground itself; one had attempted to free spectators while the other two had attended the makeshift morgue in the gymnasium. The claimants, as secondary victims, had to satisfy the criteria for the imposition of liability formulated by the House of Lords in McLoughlin v O'Brian [1983] 1 AC 410 and Alcock v Chief Constable of South Yorkshire Police [1992] AC 310. Music has historically been a key player in society and personal life. This principle was later applied in Alcock v Chief Constable of South Yorkshire Police. She suffered serious nervous shock as a result and sued the defendant who was responsible for the accident. In the case of Mcloughlin v O Brian[18], Lord Wilberforce[19] took the view that, the reasonable foreseeability should be the only criteria to determine the defendants liability towards the class of person to whom the duty of care might be owed not to inflict any psychiatric injury through nervous shock sustained by reason of physical injury or peril to another. The father immediately started helping his son to release his trapped foot out. In this case the plaintiff was exposed to asbestos dust. If the claimant was a rescuer who went to the aid of others involved in an accident, they will only be defined as a primary victim if they were, or reasonably believed themselves to be, in danger. Others identified bodies in temporary constructed morgues in the stadium. The plaintiffs in the case were police officers who suffered psychiatric injury after witnessing the Hillsborough stadium disaster. Employment > Health and safety; They could only recover if they were exposed to physical danger as primary victims. In-house law team, White and Others v Chief Constable of the South Yorkshire Police [1999] 2 AC 455, NEGLIGENCE PSYCHIATRIC DAMAGE LIABILITY TO RESCUERS DISTINCTION BETWEEN PRIMARY AND SECONDARY VICTIMS. A live television broadcast of that match was running from the ground. 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. In those cases the court still allowed the claimants to establish a claim and recover damages for psychiatric injury notwithstanding the fact that the secondary victims were not actually present at the scene of the accident. . Essays, case summaries, problem questions and dissertations here are relevant to law students from the United Kingdom and Great Britain, as well as students wishing to learn more about the UK legal system from overseas. X CsGPL)8eDD(!#V+x 6g9%RlTJ%R "XL9$Q)pTFb%irDs!(;wx*9y_yr:!,y|(*ch1Y.qT%f#R4xSn"4;I.lMO.d==Z:B|dU6t()M.|^~,fmO'8\W?O@OVC\%rESn,IPx$|`S|}KBn|oX]vhaa\]ncWi=tMGcvg7v~M&ClWAb]n~_uuzAU60\T!lnV_ '0HPT l#H:+pQ )cmlu-'46:ut(:&:h 1=i?|\A dY;dzCP(@QD}XMSV/bVS:|x(v@7|, ,mFFL [g59gNqTeB@)V&l33%f@)6a87<>Vb3{,>gkWBPz|}y.H%g -m(-1HN]>0Ns6t Z~\ L6M After that she found her husband injured and covered with mud and oil. The law on recovery of damages for psychiatric illness is entirely based on common law. Her claim was struck out, but restored on appeal. All of the aforementioned cases demonstrate clearly that claims relating to nervous shock are indeed highly complex and, in my opinion, some of the outcomes seriously flawed. foreseeability of psychiatric shock needed to be considered. To export a reference to this article please select a referencing stye below: Mental Health relates to the emotional and psychological state that an individual is in. 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). [20] Michaell A Jones, Liability for Psychiatric Illness More Principle, Less Subtlety? [1995] 4 Web JCLI. 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 . Only recognisable psychiatric illness would qualify for in such claims. The issue of communication by television was raised but not adequately dealt with. Disclaimer: This dissertation has been written by a student and is not an example of our professional work, which you can see examples of here. According to him it was a matter of common sense that-the defendant while backing his taxicab have not reasonably foreseen any personal injury to the claimant who witnessed an accident and suffered nervous shock from a house some seventy to eighty yards away up a side street. It was held by the court that the claimant was entilted to establish a claim and recover damages for psychitaric injury as it was reasonably foreseeable by the defendant[63]. After the dismissal from the Court of Appeal, ten of the claimants made an appeal to the House of Lords against the decision given by the Court of Appeal. But, the chief constable of South Yorkshire police claimed that they did not owe any duty of care to the claimants. Afterwards she went down to the corridor and came across one of her children crying who had fer face cut and discoloured with mud and soil. In this instance police officers were seeking compensation on the basis that they had suffered psychiatric illness as a result of rescuing victims after the crush. The boy sustained a very minor injury and the damage to his tricycle was nothing serious. The floodgates argument may be a possible reason for this. was reluctant to interfere with the findings of the court and agreed with the decision given by McNair J. .Cited Rothwell v Chemical and Insulating Co Ltd and Another CA 26-Jan-2006 Each claimant sought damages after being exposed to asbestos dust. Although the policy of the court seems to pose a substantial barrier or obstacle to the success of claims of this sort, but the court has justified this policy by showing an intention to restrict wide range of potential claimants who can bring successful action. The winner - given the power to fire the next chief constable - will inevitably prevail on an anti-corruption ticket. The very moment Smith was being thrown off the van by the wind, Robertson did not in fact see what happened as he was driving. [9] NJ Mullany, Psychiatric damage in the House of Lords- Fourth time Unlucky: Page v Smith (1995) 3 Journal of Law and Medicine 112. So, however, in the light of the above case decisions it has been obvious that the secondary victim must establish proximity of relationship or close tie of love and affection in order to establish a claim for psychiatric illness. But the fact of the present case must be considered in accordance with the decision of Bourhill v Young[54] where the House of Lords provided the test-if the defendant have reasonably foreseen any damage to the claimant then he owes a duty of care and liable for negligently causing personal damage. Sixteen separate actions were brought against him by persons none of whom was present in the area where the disaster occurred, although four of them were elsewhere in the ground. [31] As per Lord Oliver [1992] 1 AC 310 at page 415-416. Although the boy arrived home eventually but his mother suffered from a nervous shock[45]. Consequently, Smith was killed as he fell a few feet on to the girder below the carriageway. However, liability could not be avoided if the accident took place very close to him and was so horrific. The recent case of Crystal Taylor v A Novo (UK) Ltd CA (2013) re-examined the particular issue of proximity, together with the underlying policy considerations. . Cited Brice v Brown 1984 The plaintiff, a lady with a hysterical personality disorder since childhood, had a minor taxi accident and then developed a major psychiatric illness bizarre behaviour, suicide attempts, pleading with people to cut her head off in response to a . According to the facts of this case, the claimants (Robertson and Rough) and the primary victim (George Smith) used to work together with the defendants (Forth Road Bridge Board). In this case, the court considered chronic fatigue syndrome to be a recognizable psychiatric injury[9]. The plaintiff must show that the defendant owed duty of care not to cause the reasonably foreseeable nervous shock. Open Document. According to him, the primary victims are the category of victims who mediately or immediately was involved into the accident and the secondary victims are those who passively and unwillingly witnessed the event that involved the injury of others and subsequently sustained psychiatric illness[12]. Taylor v Somerset HA [1993] PIQR P 262 2. Copyright 2003 - 2023 - LawTeacher is a trading name of Business Bliss Consultants FZE, a company registered in United Arab Emirates. He suffered a mental breakdown in 1986, and had four months off work. Tel: 0795 457 9992, or email david@swarb.co.uk. Genearlly, the defendants are not liable to the claimants for causing psychiatric injury by means of self inflicted physical injuries. YMzBCCCBS$Gtds]1w6F[:s\mPq%`:CGqt`*SzTAER3 baP0/XlX>,eoWf0`X }@| D But he further took the view that, there is no reported English case decision where it has been established that whether a defendant owes any duty of care towards the claimant for not causing him a psychiatric injury by self inflicted injuries. Abstract. Before discussing the above cases, it is essential to give a brief outline of the term nervous shock and its history. The first is to wipe out recovery in tort for pure psychiatric injury. . The father subsequently suffered nervous shock as a result of witnessing the accident. Lord Goff said: because shock in its nature is capable of affecting so wide a range of people, there is a real need for the law to place some limitation upon the extent of admissible claims. Judgement for the case White v Chief Constable of South Yorkshire. We're here to answer any questions you have about our services. Both the judgements given by Stephenson and Griffith LJ was appreciated and therefore agreed by Cumming-Bruce LJ. The new chief constable of South Yorkshire Police has shared her "incredible pride" at leading the force. Byrne v Southern and Western RY .Co. [24] Cases and Commentary on Tort, by Barbara Harvey & John Marston, 5th Edition. See para 1.5 n 14 below. Steyn's introductory observations in his speech in R(S) v Chief Constable of the South Yorkshire Police [2004] 1 WLR 2196, which concerned DNA, emphasised the public benefits in law enforcement agencies using new technology at [1]- [2]: "1. Frost and Others v Chief Constable of South Yorkshire Police and Others (1996) The Times, 6 November, CA . Due to the accident, the claimants husband suffered from bruising and the other children suffered from severe physical injuries and shock. 34 [1996] 1 AC 155. In order for the claimant to successfully recover compensation the court needs to consider an amalgam of rules and exceptions as well as different categories of claimants, which . The House of Lord were thus called upon to revisit the distinction between primary and secondary victims set out in Alcock v Chief Constable of South Yorkshire ([1992] 1 AC 310). Similary, the defendant argued that, in the present case, the claimant was far away from the actual place of the accident and did not see what happened there. He suffered only psychiatric injury. This took place while Robertson was driving the van on a carriageway which was high above the water. Kirsty Horsey, Erika Rackley, Tort Law, 6th edn, (OUP, 2019) 210. White v Chief Constable of the South Yorkshire Police was a 1998 case in English tort law in which police officers who were present in the aftermath of the Hillsborough disaster sued for post traumatic stress disorder. It must be left to Parliament to undertake the task of radical law reform.. The case was known as Frost and Others v Chief Constable of South Yorkshire Police and Others [1997] 1 All ER 540 in the lower courts. This chapter considers the landmark decision in Alcock v Chief Constable of South Yorkshire Police [1992] 1 AC 310 concerning liability for psychiatric injury, or 'nervous shock'. Donaghue v Stevenson [1932] A.C. 532. His employers had refused to provide the increased support he requested. Interestingly, in White v Chief Constable of South Yorkshire Police the plaintiffs ( police officers ) relied on cases such as Dooley v Cammell Laird [1951] 1 Lloyds Rep 271, Galt v British Railways Board [1983] 113 NLJ 870, Wiggs v British Railways Board. He was a road worker instructed to attend by the defendant immediately after a terrible accident. White v Chief Constable of South Yorkshire. (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 best example is Boardman and Another v Sanderson and Another[56]. School King's College London; Course Title LAW 10999; Uploaded By ColonelHeatKudu28. Generally, the burden of proving such a close tie of love and affection lies with the person who wishes to establish a claim for psychiatric illness. So, the law in this area seems to be very rigid and complicated for the secondary victims. endstream endobj 165 0 obj <> endobj 166 0 obj <>/MediaBox[0 0 594.72 841.68]/Parent 162 0 R/Resources<>/Font<>/ProcSet[/PDF/Text/ImageB/ImageC/ImageI]>>/Rotate 0/Tabs/S/Type/Page>> endobj 167 0 obj <>stream All of them were connected in various ways . 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! That was a very strong windy day when the tragic accident took place. In the case of Frost v Chief Constable of South Yorkshire Police[5], the court considered the post traumatic disorder to be a recognizable psychiatric injury. The carriageway was too high that any person fell from that distance would unlikely to survive. The distinction between primary and secondary victims is well worth noting. The claimants (C) were all police officers who had been on duty within Hillsborough Stadium during the eponymous disaster, in which 95 Liverpool FC fans were killed and many others injured. That means, unless and until the court is satisfied that the secondary victim was physically present at the very scene of the accident along with the other two requirements then a claim for psychiatric illness will unlikely to be allowed[41]. The defendant relied on the decision of the case in Bourhill v Young[48] with a view to support his arguement and stated that the psychiatric injury to the mother was not reasonably foreseeable as she was not within the range of reasonable anticipation. The House of Lords reversed the Court of Appeal decision in Frost v Chief Constable of South Yorkshire [1997] 1 All ER 540, which had found that the plaintiffs were primary victims, as rescuers. [58] that the defendant was in breach of his duty of reasonable care and the claimants were entitled to recover damages. They took the big metal sheet off the bridge and subsequently put that in a pick up van. There are a number of subsequent case examples where the English courts have adhered to the requirement of close tie of love and affection as established in the Alcock case. The question was whether, having regard to the fact that she had suffered sorrow and grief it would not be to . Only Parliament could take such a step. [51] took the view that, if the two cases of Hambrook v Stokes Bros[52] and In re Polemis and Furness, withy & Co. Ltd[53]on which the claimant relied on are considered then the there is every possibility that the decision goes in favour of the claimant. . . Do you have a 2:1 degree or higher? By Christopher Gardner, QC, Lamb Chambers. Having witnessed the tragic death of Smith, both his workmates-Robertson and Rough suffered nervous shock. Television signal, actionable nuisance, property right requirement for claimants. %PDF-1.2 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. Precedent rules out this course and, in any event, there are cogent policy considerations against such a bold innovation. The House of Lords dismissed all the claimants appeals since none of them was able to satisfy the recovery criteria for psychiatric illness which had been laid down in Alcock case. Alcock v Chief Constable of South Yorkshire Police [1991] UKHL 5, [1992] 1 AC 310 is a leading English tort law case on liability for nervous shock (psychiatric injury). In England, the Dulieu v White and Sons [1901]2 KB 66 9 case was a landmark case in terms of the recovery of claims for psychiatric illnesses. Close ties of love and affection was assumed in relation to parent- child and spouse relationships. 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frost v chief constable of south yorkshire