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Claims for psychiatric harm

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Claims for Psychiatric Harm in Tort Law

Claims for psychiatric harm, also known as nervous shock, are recognized in tort law when a person suffers mental injury due to another's wrongful act or omission. Establishing liability for psychiatric harm requires meeting specific legal criteria to ensure that claims are legitimate and the harm suffered is foreseeable. The law differentiates between primary and secondary victims, each subject to different standards of proof.

Primary Victims

Primary victims are those directly involved in an incident and at risk of physical injury:

  • Foreseeability of Physical Harm: For primary victims, it is sufficient that physical harm was foreseeable. If the claimant was in the zone of danger, they can claim for psychiatric harm even if no physical injury occurred.
  • Direct Involvement: Primary victims are directly involved in the traumatic event. This includes those who were physically endangered or who reasonably believed they were in danger.

Secondary Victims

Secondary victims are those who witness a traumatic event or its aftermath but are not directly at risk of physical harm. The criteria for secondary victims are more stringent:

  • Close Relationship: The claimant must have a close tie of love and affection with the primary victim, such as a parent, child, spouse, or close partner.Proximity to the Event: The claimant must be present at the scene of the traumatic event or its immediate aftermath. This proximity in time and space is crucial for establishing liability.
  • Direct Perception: The psychiatric harm must result from the claimant's direct perception of the event or its immediate aftermath. This means witnessing the event with their own senses, rather than hearing about it from others.
  • Psychiatric Illness: The claimant must suffer a recognized psychiatric illness. Mere emotional distress or grief is insufficient; the harm must be medically recognized and diagnosable.

Case Law

Primary Victims - Page v Smith (1996)

In this case, the House of Lords held that a primary victim can claim for psychiatric harm if physical harm was foreseeable, even if no physical injury occurred. The claimant was involved in a car accident and suffered a relapse of a pre-existing psychiatric condition.

Secondary Victims - Alcock v Chief Constable of South Yorkshire Police (1992)

This case set out the strict criteria for secondary victims. The claimants, who were relatives of the victims of the Hillsborough disaster, were required to prove a close tie of love and affection, proximity to the event or its aftermath, direct perception, and a recognized psychiatric illness.

Examples

Example 1 - Primary Victim Claim

Scenario:

A worker is involved in an industrial accident where machinery malfunctions. Although the worker escapes physical injury, they develop post-traumatic stress disorder (PTSD) due to the fear of being harmed. As a primary victim, they can claim for psychiatric harm since physical harm was foreseeable.

Example 2 - Secondary Victim Claim

Scenario:

A mother witnesses her child being hit by a car and suffers severe depression as a result. She can claim for psychiatric harm as a secondary victim due to the close relationship, direct perception of the event, and recognized psychiatric illness.

Conclusion

Claims for psychiatric harm in tort law require careful consideration of the relationship between the claimant and the event, the proximity to the traumatic incident, and the nature of the psychiatric injury. The law provides distinct criteria for primary and secondary victims to ensure that only legitimate and foreseeable claims are compensated. Understanding these principles is essential for navigating claims involving mental injuries and achieving just outcomes for affected individuals.

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