The above judgment in White v The Chief Constable allowed the defendants' appeal against the 1997 Court of Appeal decision in Frost & Ors. 3 Frost v Chief Constable of South Yorkshire Police [1997] 3 WLR 1194. .Cited Mullaney v Chief Constable of West Midlands Police CA 15-May-2001 The claimant police officer was severely injured making an arrest. Alcock -v- The Chief Constable of South Yorks [1992] 1 AC 310. However, the decision in the case of Dooley V Cammen Laird preserved the distinction between primary and secondary victim. In this case, he categorized the victims in a psychiatric injury cases in to two main categories- the primary and secondary victims. Frost and Others v Chief Constable of South Yorkshire Police and Others (1996) The Times, 6 November, CA . 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]. Thus, there could be no duty of care owed to C for purely psychiatric harm, as they were not at any point in any physical danger. The plaintiffs were not primary victims as they we were not within the range of foreseeable physical injury and their psychiatric harm was a result of . Due to the accident, the claimants husband suffered from bruising and the other children suffered from severe physical injuries and shock. White v Chief Constable of South Yorkshire. 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. In modern times, the issue of liability for nervous shock still remains a contentious issue. 34 [1996] 1 AC 155. of Ireland (1884) illustrate that even though no physical injury occurred, the plaintiff was clearly in physical danger and therefore was allowed recovery. Frost v Chief Constable of Yorkshire Police [1997] 3 WLR 1194. It was the case of King v Phillips[44] in which the claimant having suffered psychiatric illness failed to establish a claim against the defendant as the court considered that the victim was far away from the accident. In order to establish a claim and recover damages for psychiatric illness the secondary victims must satisfy the proximity of relationship[15]. Section A The codification of directors duties was an unnecessary step. 2 claims. (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. Mental Health of Adolescent and Young Adult Cancer Survivors. Evidence Law - Admissibility of Evidence Essays. Although, according to the guidelines of television broadcasting, none of the television channels highlighted any scenes that relate to the dying or suffering of the spectators in that disaster[24]. In this case the plaintiff was exposed to asbestos dust. Cited Best v Samuel Fox and Co Ltd 1952 The court considered liability for injury to secondary victims. Judgment - White and Others v. Chief Constable of South Yorkshire and Others continued. The House considered claims by police officers who had suffered psychiatric injury after tending the victims of the Hillsborough tragedy. Frost and Others v Chief Constable of South Yorkshire Police and Others (1996) The Times, 6 November, CA. But, according to the facts of the present case, the defendant had the knowledge that the claimant was not far away from the place of the accident, so therefore it was reasonably forseeable by the defendant that the father would be shocked after witnessing the accident in which his little son was involved. ( as what happened in this particular case ) . The courts both in England and Ireland have endeavoured to limit the scope of liability for psychiatric illness, by establishing a set of criteria that a claimant/s must fulfil in order to be entitled to compensation. In Alcock case, the House of Lords took the view that- the secondary victims will be entitled to establish a claim and recover damages for psychiatric injury if he can establish the fact that, the defendant could have reasonably foreseen that he would suffer from a psychiatric illness due to the negligent act as there was proximity of relationship between both the primary and secondary victims. He became so upset with his personal life and as a result his marriage life was affected. [12] Teff, H (1992) Liability for Psychiatric Illness after Hillsborough 12 Oxford Journal of Legal studies 440. .Cited Waters v Commissioner of Police for the Metropolis HL 27-Jul-2000 A policewoman, having made a complaint of serious sexual assault against a fellow officer complained again that the Commissioner had failed to protect her against retaliatory assaults. Acting for the Chief Constable of the South Yorkshire Police on the Hillsborough litigation in relation to the Inquests, Alcock (family PTSD claims) and Frost/White (police PTSD claims); Court of Appeal win in Webster v Ellison Circlips on automatic strike out. They would allow claims for pure psychiatric damage by mere bystanders: see (1997) 113 LQR 410, 415. The court considered her to be outside the area of potential danger. Many of the claimants witnessed horrific images and scenes of carnage on the television . Having witnessed the accident, the claimant later suffered from post traumatic stress disorder. 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. It is an important matter of discussion what is actually meant by psychiatric illness or if there is any specific definition of psychiatric illness under the English law of tort. The claim was rejected by the House of Lords on the basis that none of the claimants could be considered "primary . Take a look at some weird laws from around the world! l'LCocI2Vp.0c The class of potential claimants is restricted among the secondary victims, especially for those who have close relationships with the primary victims. To satisfy physical proximity to the accident or its immediate aftermath might be considered as another major obstacle for the secondary victims where there is an issue of establishing a claim for the psychiatric illness. 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 . The plaintiffs sought damages for nervous shock. Held: The claim failed: these claimants have no . White (Frost) v Chief Constable of South Yorkshire Police [1999] 2 AC 455 (Hillsborough, police on duty) The Control Mechanisms - Alcock 1. Only full case reports are accepted in court. After the Alcock case, the English courts have adopted a further strict approach of the requirement of close tie of love and affection when there is an issue of successful action for psychiatric illness by the secondary victims. . View history. The law has imposed lots of requirements for the secondary victims before they can successfully make a psychiatric injury claim. [58] that the defendant was in breach of his duty of reasonable care and the claimants were entitled to recover damages. hYn86 ,tV!%TvIrD9f%E0jBA%r`$)8 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 Supreme Courts decision was to disallow recovery as there was no more than a remote risk of contracting a disease. .Cited Rothwell v Chemical and Insulating Co Ltd and Another CA 26-Jan-2006 Each claimant sought damages after being exposed to asbestos dust. Lord Bridge in McLoughlin v OBrian required that a plaintiff must not merely suffer grief, distress or any other normal emotion, but a positive psychiatric illness. No plagiarism, guaranteed! He brought an action for negligently inflicted psychiatric illness against the defendants. The most recent of which was Frost v The Chief Constable of South Yorkshire which resulted from the Hillsborough tragedy. In Alcock v Chief Constable of South Yorkshire (1992) 1 AC 310 the ordinary rules of negligence were applied to allegedly negligent crowd control by the police. It is of paramount importance that the law enforcement The injuries were psychiatric, being suffered when they witnessed a crash from the ground. 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. Copyright 2003 - 2023 - LawTeacher is a trading name of Business Bliss Consultants FZE, a company registered in United Arab Emirates. Nervous shock is a term used in English law to denote psychiatric illness or injury inflicted upon a person by intentional or negligent actions or omissions of another. 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. Download Citation | Frost (or White) v Chief Constable of South Yorkshire Police [1999] 2 AC 455 | Essential Cases: Tort Law provides a bridge between course textbooks and key case judgments . On the basis of the facts of this case, three preliminary questions arose which were as follows: The first issue was, whether the defendant (the primary victim/ son of the claimant) owes any duty of care towards the claimant (secondary victim) for not causing any psychiatric injury by self inflicted physical injuries. .Cited Calvert v William Hill Credit Ltd ChD 12-Mar-2008 The claimant said that the defendant bookmakers had been negligent in allowing him to continue betting when they should have known that he was acting under an addiction. 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 . Having heard this, the claimant ran approximately hundred yards from her place in order to see her son who was eventually died. Copyright 2003 - 2023 - UKDiss.com is a trading name of Business Bliss Consultants FZE, a company registered in United Arab Emirates. Is there any liability for self inflicted physical injury which caused the claimants psychiatric illness? CJ Keane criticized the logic of distinguishing between psychiatric illnesses resulting from a traumatic event as opposed to suffering grief in its aftermath. 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. He further considered that, such a proximity relationship or close tie of love and affection might exist between the family members or friends. [19] As per Lord Wilberforce [1883] 1 A.C. 410 at Page 411. . Do you have a 2:1 degree or higher? complexities encountered by the court in Frost in applying the principles laid down by Alcock v Chief Constable of the South Yorkshire Police14 and Page v Smith15 are also highlighted. He suffered only psychiatric injury. But, it has been seen from some of the above case decisions that, even after satisfying the requirement of proximity of relationship, the court still did not allow the secondary victims claim for psychiatric injury. Interestingly, it was also stated the purpose of the visit was to identify the body and not to aid the injured or rescue victims as in other compensation cases. So, finally, the House of Lord dismissed the appeal made by the claimant. . 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. Accordingly, in the case of Robertson and Rough v Forth Road Bridge Joint Board[35], the claimants brought an action against the defendants for a horrible disaster that took place on the Forth Road Bridge. ~M}o"bR[ A\euA. The best example is Boardman and Another v Sanderson and Another[56]. Judgement for the case White v Chief Constable of South Yorkshire. Having witnessed the tragic death of Smith, both his workmates-Robertson and Rough suffered nervous shock. 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. Fletcher v Commissioners for Public Works [2003] 2 I.L.R.M.94. 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. The outcome of this case is particularly note worthy. The claimants alleged that the police constable were responsible for everything who failed to control the crowed and consequently the horrible disaster took place which not only caused the death or injury to the spectators but also caused psychiatric illness to the relatives of the deceased or injured as they were watching or hearing the news of the disasters. Hall v gwent healthcare nhs trust 2004 qb c hall was. The claimants eight year old son was very close to the near side door of the car and was playing there. 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 . 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. It seems apparent from the Alcock case judgments that the court will only emphasize on close tie of love and affection before allowing any secondary victims to establish a claim and recover damages for psychiatric illness. 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. Kirsty Horsey, Erika Rackley, Tort Law, 6th edn, (OUP, 2019) 210. He argued that, in Bourhills case, the fishwife was not entitled to recover damages for psychiatric illness since she did not see the actual accident at the time it took place but only saw the outcome of it afterwards. The horrible accident took place when the employees were removing a big thin piece of metal sheeting which was lying on the south-bound carriageway. No issues of. The secondary victims are required by the existing law to satisfy or establish additional criteria before they can bring a claim for psychiatric injury against the negligent defendant which has been discussed elaborately in the later chapters. Nor is any duty of care owed to a rescuer lacking ordinary courage. Hicks v Chief Constable of the South Yorkshire Police [1992] 2 All ER 65. not medically recognised condition: fear, it is a normal emotion; . (White (Frost) v Chief Constable of S Yorks, pp 500 and 511) The Clinical Negligence cases 1. Television signal, actionable nuisance, property right requirement for claimants. While backing his car out of the garage, the defendant ran over the feet of the little boy which caused him injuries. In Frost v Chief Constable of South Yorkshire Police [1999] 2 AC 455, the House of Lords applied that distinction to police officers (and others) who were not themselves within the zone of physical danger caused by the defendant's negligence, but had to deal with the consequences of catastrophic harm to others in the course of their duties . [70] As per Griffith LJ [1981] 1 All ER 809 at page 829. White v Chief Constable of the Yorkshire Police [1998] 3 WLR 1509. In this case, he categorized the victims in a psychiatric injury cases in to two main . The House considered claims by police officers who had suffered psychiatric injury after tending the victims of the Hillsborough tragedy. His widow claimed in nervous shock, saying that it had eventually led to his own death. N>7>@s!z9@-w9Hy^O1? M:fXxKGkYqLfX A Ai>|N_*HbOsu.7B ovRl-#GQcLXH`{70l191X?@j`P02:vKX @9E. The present law in this area seems to be very rigid and restrictive for the secondary victims. The court held that the defendant was liable for negligence and allowed the claimant to recover damages for psychaitric illness as the mental injury to the claimant was reasonably foreseeable by the defendant[65]. Two of the claimants found their relatives or friend severely injured whereby one of them had his relative who escaped unhurt. 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. . He continued that, the claimants nervous shock was too remote as a head of damage. The only prudent course is to treat the pragmatic categories as reflected in in authoritative decisions such as the Alcock case and Page v. Smith as settled for the time being, but by and large to leave any expansion or development in this corner of the law to Parliament. However, to satisfy the proximity of relationship with the primary victims might be considered a major obstacle for the secondary victims when there is an issue of establishing a claim for the psychiatric illness. All of them were connected in various ways . For example, in Hinz v Berry[3], the court recognized morbid depression as a recognizable psychiatric illness. Like the case of Alcock v Chief Constable of South Yorkshire, this case arose from the disaster that occurred at Hillsborough football stadium in Sheffield in the FA cup semi-final match between Liverpool and . It was held by Salmon J. The victims were taken to the nearest hospital by that neighbour. The Court of Appeal's judgment has been discussed at some length by the present authors in an earlier article, "Nervous Shock, Rescuers and Employees - Primary or Secondary Victims?" [1998] SLJS 121. The Second Defendant relies on the view of the majority of the House of Lords in White v Chief Constable of South Yorkshire [1999] 2 AC 455 (also known as Frost v Chief Constable of South Yorkshire) that, for a rescuer to be regarded as a primary victim, it must be shown that they were exposed to the risk of physical injury or reasonably . In the case of Frost v Chief Constable of South Yorkshire Police [5], . We and our partners share information on your use of this website to help improve your experience. He successfully adduced evidence that there was a very close and intimate relationship between him and his half brothers[34]. 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. His Lordship further continued that, the present case is distinguishable from the case of King v Phillips[61]. However, in this case, it was held by the House of Lords that, none of the appellants were entitled to establish a claim and recover damages for psychiatric illness. In this case, the claimant argued that he was entitled to recover damages for psychiatric injury as he satisfied all the additional criteria for recovery which have been laid down in the case of Alcock[38]. 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. The Court of Appeal (by a majority) found in favour of all but one of the officers. 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. 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