in the Court of Appeal in the instant case, ante, pp. My Lords, in each of these appeals the question raised is whether the defendant is to be held responsible for psychiatric injury suffered by a plaintiff who was not himself or herself directly involved in the accident (for which, for present purposes, the defendant accepts responsibility) but who was connected to a victim by the bonds of an affectionate relationship such that he or she suffered extreme shock or anguish leading to the condition of which the plaintiff complains. 6.9 Judgment on Withdrawal – part - rule 52 EMPLOYMENT TRIBUNALS Claimant: Ms S Morgan Respondent: The Chief Constable of South Yorkshire Police JUDGMENT The claims at paragraphs 5 and 16 of the “Discussion” section of the Order of 29 January 2020 are dismissed following a … Accordingly, the judge did not carry out the requisite close scrutiny of their relationship. House of Lords. Alcock and others claimed damages for the psychiatric harm they suffered as a result of experiencing such a horrific event. In a case of negligence causing physical injury to an employee or to a road user reasonable foreseeability may well be the only criterion by which liability comes to be judged. Alcock and Others v Chief Constable of South Yorkshire Police. AUTHOR: Asmi Chahal, 1st year, THE ICFAI UNIVERSITY, ICFAI LAW SCHOOL, DEHRADUN. Shock is no longer a variant of physical injury but a separate kind of damage. Study Resources. And, in the end, it has to be accepted that the concept of "proximity" is an artificial one which depends more upon the court's perception of what is the reasonable area for the imposition of liability than upon any logical process of analogical deduction. that although both the tests of reasonable foreseeability and proximity were satisfied, a duty of care was precluded by considerations of public policy and (Griffiths L.J.) The plaintiffs, being relatives and friends of the deceased, inter alia suffered nervous shock having seen the events either from within the ground, or from outside or at home on . I would, however, place in the category to members of which risk of psychiatric illness was reasonably foreseeable Mr. and Mrs. Copoc, whose son was killed, and Alexandra Penk, who lost her fianc e. In each of these cases the closest ties of love and affection fall to be presumed from the fact of the particular relationship, and there is no suggestion of anything which might tend to rebut that presumption. But, as I shall endeavour to show, the law in this area is not wholly logical and whilst having every sympathy with the plaintiffs, whose suffering is not in doubt and is not to be underrated, I cannot for my part see any pressing reason of policy for taking this further step along a road which must ultimately lead to virtually limitless liability. The law has developed incrementally. No plaintiff lost a spouse. Lord Oliver made one of the first attempts to distinguish between secondary and primary victims in tort law. If such relationship is not established the claim will fail. In that case the primary victims of the accident caused by the respondent's negligence were the husband and two children of the appellant, who were injured, and another child of hers who was killed. I, too, would therefore dismiss these appeals. In the result, he found in favour of ten out of the sixteen plaintiffs before him and against six of them. Or it may be asked whether injury of the type with which these appeals are concerned can ever be considered to be reasonably foreseeable where the relationship between the plaintiff and the primary victim is more remote than that of an established category. Policy considerations such as this could, I cannot help feeling, be much better accommodated if the rights of persons injured in this way were to be enshrined in and limited by legislation as they have been in the Australian statute law to which my noble and learned friend, Lord Ackner, has referred. 421-423: Lord Bridge of Harwich, with whom Lord Scarman agreed, at p. 431D-E, appears to have rested his finding of liability simply on the test of reasonable foreseeability of psychiatric illness affecting the plaintiff as a result of the consequences of the road accident, at pp. Frost v Chief Constable of Yorkshire Police [1997] 3 WLR 1194. 73; and at first instance inRedenaktiebologet v.Transatlantik [1991] 3 All E.R. Lord Bridge propounded simply a criterion of the reasonable foreseeability by the defendant of the damage to the plaintiff which had occurred without necessarily invoking physical presence at or propinquity to the accident or its aftermath or any particular relationship to the primary victim as limiting factors, although, of course, clearly these elements would be important in the determination of what, on the facts of any given case, would be reasonably foreseeable. The Claimant alleged that in April 1998 police officers in Sheffield unlawfully searched and detained him and thereafter maliciously prosecuted him for affray, assault and criminal damage. In this chapter, I argue that Alcock was an essentially conservative LORD TEMPLEMAN. There she was told that one of the children had been killed, and saw her husband and the other two in a distressed condition and bearing on their persons the immediate effects of the accident. The means by which the shock is caused constitutes a third control, although in these appeals I find it difficult to separate this from proximity. Verdict passed by the honourable judges in this case is still considered to be a good judgment in law and henceforth has been applied to many other cases. My Lords, I have enjoyed the advantage of reading in draft the speeches of your Lordships, all of whom have reached the same conclusion, namely, that these appeals should be dismissed. This case raises novel and important issues … Into the same category, I believe, fall those cases such as Dooley v. Cammell Laird & Co. Ltd. [1951] 1 Lloyd's Rep. 271, Galt v. British Railways Board (1983) 133 N.L.J. The diversity of view arose at the next stage, that is to say that of ascertaining whether the relationship between the plaintiff and the primary victim was such as to support the existence of such a duty. 19th Jun 2019 Case Summary Reference this In-house law team Jurisdiction (s): UK Law Alcock v Chief Constable of South Yorkshire 1 AC 310 NEGLIGENCE – PSYCHIATRIC DAMAGE – TRAUMATIC EVENT WITNESSED INDIRECTLY – DISTINCTION BETWEEN PRIMARY AND SECONDARY VICTIMS FACTS. But such a causal link is assumed for the purposes of these appeals. [1998] SLJS 121. Alcock v Chief Constable of South Yorkshire Police [1992] 1 AC 310 is a leading English tort law case on liability for nervous shock (psychiatric injury). Outer Temple Chambers | Personal Injury Law Journal | July/August 2018 #167 In McLoughlin v. O'Brian [1983] 1 AC 410, a wife and a mother suffered nervous shock after seeing her husband and children in a hospital to which they had been taken after a road accident. In Jaensch v. Coffey (1984) 155 C.L.R. The principal argument in the appeal has centred round the question whether, as the plaintiffs contend, the decision of this House in McLoughlin v. O'Brian [1983] 1 AC 410, establishes as the criterion of a duty owed by the defendants to the plaintiff a simple test of the foreseeability of injury of the type in fact sustained or whether, as the defendant maintains, that case imports also a necessary requirement, either as a matter of public policy or as a measure of proximity, of the existence of some close blood or marital relationship between the appellants and the victims of the negligent conduct. Respondent admitted negligence. The case centred upon the liability of the police for the nervous shock suffered in consequence of the events of the Hillsborough disaster. In another judgment (Frost v Chief Constable of South Yorkshire Police [1999] 2 AC 455), Lord Hoffman said that "the search for principle was called off [in Alcock]". My Lords, if sympathy alone were to be the determining factor in these claims, then they would never have been contested. In each case damages are sought for psychiatric illness, which, for present purposes, must be assumed to have been caused by the nervous impact on the plaintiff of the death or injury of a primary victim with whom he or she had a strong bond of affection. In the latter case the plaintiff, after learning of a motor accident involving her husband and three of her children about two hours after it had happened, went to the hospital where they had been taken. These images provided no doubt the matrix for imagined consequences giving rise to grave concern and worry, followed by a dawning consciousness over an extended period that the imagined consequence had occurred, finally confirmed by news of the death and, in some cases, subsequent visual identification of the victim. He then considered the arguments on policy which had led the Court of Appeal to reject the plaintiff's claim, and concluded, at p. 421, that they were not of great force. The case centred upon the liability of the police for the nervous shock suffered in consequence of the events of the Hillsborough disaster . Inevitably the impact of the event and its aftermath, whether immediate or prolonged, is going to be felt in greater or lesser degree by those with whom the victim is connected whether by ties of affection, of blood relationship, of duty or simply of business. Alcock v Chief Constable of South Yorkshire Police [1991] Facts. Nor can it be the mere suddenness or unexpectedness of the event, for the news brought by a policeman hours after the event may be as sudden and unexpected to the recipient as the occurrence of the event is to the spectator present at the scene. The Chief Constable of South Yorkshire has admitted liability in negligence in respect of the deaths and physical injuries. This chapter considers the landmark decision in Alcock v Chief Constable of South Yorkshire Police 1 AC 310 concerning liability for psychiatric injury, or ‘nervous shock’. In any event only two of them were present in the ground and the remainder saw the scenes on simultaneous or recorded television. Lord Wilberforce, at p. 422, appears to have favoured the last of these three approaches, but found it, in the event, unnecessary to determine the boundary since the case then before the House concerned a claim within a category which had already been clearly established. The psychiatric injury must be caused by a shocking event. 870, and Wigg v. British Railways Board, The Times, 4 February 1986, where the negligent act of the defendant has put the plaintiff in the position of being, or of thinking that he is about to be or has been, the involuntary cause of another's death or injury and the illness complained of stems from the shock to the plaintiff of the consciousness of this supposed fact. 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. All were agreed that actually witnessing or being present at or near the scene of an accident was not essential to ground liability in an appropriate case, but that the duty might equally be owed to one who comes upon the immediate aftermath of the event. If, for instance, the primary victim is himself 75 per cent. In the Court of Appeal Rose L.J. that an award of damages for shock caused by the sight of an accident may be restricted to cases where the plaintiff is "a close relative.". It is, however, worth noting that the pursuer's claim was not dismissed in limine on the ground that she was no more than, at highest, a mere spectator. The physical proximity of the pursuer to the point of collision was outside the area in which the deceased could reasonably have contemplated any injury to her and that answered both the question of whether there was reasonable foresight and whether there was any relationship with the deceased inferring a duty of care. and Deane J. in Jaensch v. Coffey, (1984) 155 C.L.R. R (on the application of Chief Constable of South Yorkshire Police) v Kelly In this case, the interested party, K, was a serving police officer who had developed post-traumatic stress disorder. Therefore events witnessed on television, for example, will not succeed. He has further accepted that each of the plaintiffs has suffered some psychiatric illness. In this case, hearing about the disaster on radio or TV reports subsequently did not satisfy condition but the police department was held liable for negligence in duty to care. State Of Bombay And Another v. F. N. Balsara (AIR 1951 SC 318), Arup Bhuyan V. State Of Assam [2011] 3 SCC 377. Alcock v Chief Constable of South Yorkshire Police: lt;p|>|Template:Infobox Court Case| ||||Alcock v Chief Constable of South Yorkshire Police|| [199... World Heritage Encyclopedia, the aggregation of the largest online encyclopedias available, and the most definitive collection ever assembled. Once you create your profile, you will be able to: Claim the judgments where you have appeared by linking them directly to your profile and maintain a record of your body of work. Cup. The answer cannot, I think, lie in the greater foreseeability of the sort of damage which the plaintiff has suffered. It must, as it seems to me, be attributable simply to the fact that such persons are not, in contemplation of law, in a relationship of sufficient proximity to or directness with the tortfeasor as to give rise to a duty of care, though no doubt "policy," if that is the right word, or perhaps more properly, the impracticability or unreasonableness of entertaining claims to the ultimate limits of the consequences of human activity, necessarily plays a part in the court's perception of what is sufficiently proximate. They sought damages, some of them for personal injuries by way of nervous shock and some in the light of psychiatric injury having seen the match on television, and knowing that their relatives were in the crowd which was caused by the negligence of the police department who was responsible for the crowd control. The necessary element of proximity between plaintiff and defendant is furnished, at least in part, by both physical and temporal propinquity and also by the sudden and direct visual impression on the plaintiff's mind of actually witnessing the event or its immediate aftermath. The fact that the injury suffered is psychiatric and is caused by the impact on the mind of becoming involved in personal danger or in scenes of horror and destruction makes no difference. So, for instance, in Kirkham v. Boughey [1958] 2 Q.B. Into the same category, as it seems to me, fall the so called "rescue cases." Alcock & ors v Chief Constable of South Yorkshire AC 310 House of Lords This case arose from the disaster that occurred at Hillsborough football stadium in Sheffield in the FA cup semi-final match between Liverpool and Nottingham Forest in 1989. As I read the evidence, the shock in each case arose not from the original impact of the transmitted image which did not, as has been pointed out, depict the suffering of recognisable individuals. R (on the application of Chief Constable of South Yorkshire Police) v Kelly In this case, the interested party, K, was a serving police officer who had developed post-traumatic stress disorder. 73, reversed on appeal [1992] 2 All E.R. Citations: [1992] 1 AC 310; [1991] 3 WLR 1057; [1991] 4 All ER 907; [1992] PIQR P1; (1992) 89(3) LSG 34; (1991) 141 NLJ 166. In such a case he can be properly said to be the primary victim of the defendant's negligence and the fact that the injury which he sustains is inflicted through the medium of an assault on the nerves or senses does not serve to differentiate the case, except possibly in the degree of evidentiary difficulty, from a case of direct physical injury. 386G-387A. Get 1 point on providing a valid sentiment to this 65 and Ravenscroft v. Rederiaktieb laget Transatlantic [1991] 3 All E.R. THE CHIEF CONSTABLE OF SOUTH WALES POLICE -and- SECRETARY OF STATE FOR THE HOME DEPARTMENT -and- ... Judgment Approved by the court for handing down R (Bridges) v CCSWP and SSHD Lord Justice Haddon-Cave and Mr. Justice Swift: A. 338, a husband, whose wife had been severely injured in a road accident as a result of the defendant's negligence, failed to recover damages for a reduction in his earnings due to his having, because of his anxiety for his wife, declined to resume more remunerative employment abroad; although in that case Diplock J. was prepared to allow his claim for the expenses incurred in providing medical care for his wife on the ground that the plaintiff was under a legal duty to provide it. Until 1983 however there had in England been no case in which a plaintiff had been able to recover damages for nervous shock when the event giving rise to the shock had occurred out of sight and out of earshot. Interact directly with CaseMine users looking for advocates in your area of specialization. The primary difficulty here was that of establishing the foreseeability of the injury which the plaintiff suffered rather than the proximity of her relationship to the defendant, who owed her the same duty as he owed to any other users of the highway. In neither of these cases was there any evidence of particularly close ties of love or affection with the brothers or brother-in-law. They would need to satisfy strict eligibility criteria to claim. Equally obviously, the foreseeability of such injury to such a person will be more difficult to establish than similar injury to a spouse or parent of the primary victim. My Lords, for my part, I have not felt able to accept either of these two extreme positions nor do I believe that the views expressed in McLoughlin v. O'Brian [1983] 1 AC 410, are as irreconcilable as has been suggested. This seems to me to be a very different situation from that in which a relative goes within a short time after an accident to rescue or comfort a victim. His claim was not presented upon the basis that there was such a close and intimate relationship between them, as gave rise to that very special bond of affection which would make his shock-induced psychiatric illness reasonably foreseeable by the defendant. 's foregoing limitation was disapproved by the majority of the Court of Appeal who held that a mother who had sustained nervous shock as a result of fear for the safety of her three children due to the movement of an unmanned lorry had a cause of action against the owner of the lorry. Had she sustained bodily injury from the incursion there could never have been the slightest doubt about the defendant's liability and the fact that what brought about the injury was not an actual contact but the imminent threat to her personally posed by the defendant's negligence could make no difference to the result. 352-354: The question of liability in negligence for what is commonly, if inaccurately, described as "nervous shock" has only twice been considered by this House, in Bourhill v. Young [1943] AC 92 and in McLoughlin v. O'Brian [1983] 1 AC 410. McLoughlin v. O'Brian [1983] 1 AC 410 was a case which itself represented an extension not, as I think, wholly free from difficulty and any further widening of the area of potential liability to cater for the expanded and expanding range of the media of communication ought, in my view, to be undertaken rather by Parliament, with full opportunity for public debate and representation, than by the process of judicial extrapolation. 549, 578-586, per Deane J. In these circumstances none of the plaintiffs having satisfied both the tests of reasonable foreseeability and of proximity I would dismiss all the appeals. Copoc and others (Appellants) v. Wright (sued as Chief. The claimants were all classed as secondary victims since they were not in the physical zone of danger. Before confirming, please ensure that you have thoroughly read and verified the judgment. Take, for instance, the case of a mother who suffers shock and psychiatric injury through witnessing the death of her son when he negligently walks in front of an oncoming motor car. Upon Report from the Appellate Committee to whom was referred the Cause Alcock and others against Wright (sued as Chief Constable of the South Yorkshire Police) and Copoc and others against Wright (sued as Chief Constable of the South Yorkshire Police), That the Committee had heard Counsel as well on Monday the 7th as on Tuesday the 8th, Wednesday the 9th, Thursday the 10th and … It has yet to include psychiatric illness caused by the accumulation over a period of time of more gradual assaults on the nervous system.”. HOUSE OF LORDS. The quality of brotherly love is well known to differ widely - from Cain and Abel to David and Jonathan. It is well established that the defendant owes a duty of care not only to those who are directly threatened or injured by his careless acts but also to those who, as a result, are induced to go to their rescue and suffer injury in so doing. 912, the plaintiff recovered damages for nervous shock sustained as a result of his prolonged rescue efforts at the scene of a serious railway accident which had occurred near his home. But I do not think that too much should be read into these remarks. Alcock v Chief Constable of South Yorkshire Police concerned sixteen unsuccessful claims for psychiatric injury (PI) resulting from the Hillsborough disaster. The south Yorkshire police force that was responsible for crowd control at the match had negligently directed a large number of spectators to one end of the stadium into a caged pen as the result of which a fatal crash took place, succeeded by a stampede killing 95 people and physically injuring many others. 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