Page v Smith [1995] UKHL 7

House of Lords

PageAppellantSmithRespondent
Lord Keith of KinkelDate 11 May 1995
It is Ordered and Adjudged, by the Lords Spiritual and Temporal in the Court of Parliament of Her Majesty the Queen assembled, That the said Order of Her Majesty's Court of Appeal of the 30th day of March 1994 complained of in the said Appeal be, and the same is hereby, Set Aside and that the Order of the Honourable Mr. Justice Otton of the 22nd day of October 1992 be, and the same is hereby, Restored save as to the issue of causation and as to costs: And it is further Ordered. That the issue of causation be remitted back to the Court of Appeal for determination: And it is also further Ordered. That the respondent do pay to the appellant his costs in this House, the amount of such costs to be certified by the Clerk of the Parliaments if not agreed between the parties; and that the costs below be determined by the Court of Appeal.Cler: Parliamentor:

HOUSE OF LORDS

OPINIONS OF THE LORDS OF APPEAL FOR JUDGMENT

IN THE CAUSE

PAGE (APPELLANT)

v.

SMITH (RESPONDENT)

ON 11TH MAY 1995

Lord Keith of Kinkel Lord Ackner Lord Jauncey of Tullichettle Lord Browne-Wilkinson Lord Lloyd of Berwick

LORD KEITH OF KINKEL

My Lords,On 24 July 1987 the plaintiff, Mr. Page, was involved in a motor accident. He was driving his Volvo car along a road in Bury St. Edmunds when the defendant, Mr. Smith, driving his Datsun car in the opposite direction, cut across to enter a side road. A collision occurred. The plaintiff sustained no bodily injury. Neither did the defendant or his wife and child who were with him in his car. However, the plaintiff had for a very long time been suffering from a condition variously described as myalgic encephalomyelitis (ME), or chronic fatigue syndrome (CFS) or post viral fatigue syndrome (PVFS), which had manifested itself from time to time with different degrees of severity. The plaintiff had suffered a particularly severe attack in March 1987, apparently as a result of a viral infection, but his evidence was that he was recovering from it and hoped to be able to return to his work as a teacher in September 1987. The plaintiff took proceedings against the defendant claiming damages for personal injuries caused by the defendant's negligence. His case was that his condition of what I shall for convenience refer to as CFS had as a result of the accident become chronic and permanent so that he would never be able to work again. Trial took place before Otton J., who on 22 December 1992 found in the plaintiff's favour and awarded him damages of £162,153. The defendant appealed, and on 30 March 1994 the Court of Appeal (Ralph Gibson, Farquharson and Hoffmann L.JJ.) reversed the decision of Otton J. and entered judgment for the defendant. The plaintiff now appeals to your Lordships' House.

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The question primarily at issue is whether in claims for damages due to nervous shock it is in all cases incumbent upon the plaintiff to prove that injury by nervous shock was reasonably foreseeable by the defendant, or whether it suffices, where the plaintiff was himself involved in an accident, for him to prove that personal injury of some kind was reasonably foreseeable as a result of it. The trial judge took the latter view but the Court of Appeal unanimously took the former. Ralph Gibson L.J. was in addition of the opinion that the plaintiff had not proved that his recrudescence of CFS was caused by the accident. The other two members of the Court of Appeal did not deal with that matter.It is necessary at the outset to particularise what is meant by "nervous shock," such as may result in liability for damages. The decided cases indicate that it means a reaction to an immediate and horrifying impact, resulting in some recognisable psychiatric illness. There must be some serious mental disturbance outside the range of normal human experience, not merely the ordinary emotions of anxiety, grief or fear. As was observed by Lord Oliver of Aylmerton in Alcock v. Chief Constable of South Yorkshire Police [1992] 1 AC 310 , 407, the cases divide broadly into two categories, those in which the plaintiff was involved as a participant in the incident which gave rise to the action, and those in which the plaintiff was a witness to injury caused to others, or to the immediate aftermath of an accident to others. The first category includes Dulieu v. White & Sons [1901] 2 KB 669 , where the plaintiff was terrified by a cart and horses bursting into the public house where she was employed, and Schneider v. Eisovitch [1960] 2 Q.B. 430. where the plaintiff was herself injured in the accident which resulted in the death of her husband. Cases in the second category include Hambrook v. Stokes Brothers [1925] 1 K.B. 141, where a mother was terrified by the prospect of injury to her children from a runaway lorry, and Mcloughlin v. O'Brian [1983] 1 AC 410 , where the plaintiff shortly after a road accident saw her husband and children badly injured in hospital. Liability for negligence depends upon proof both that it was reasonably foreseeable that injury would result from the act or omission called in question and that a relationship of proximity existed between plaintiff and defendant. Where the plaintiff is personally involved in a terrifying incident proof of proximity presents no problem. Where, however, the plaintiff is what may be described as a secondary victim proximity may be very difficult to establish . It was held to exist in McLouglin v. O'Brian [1983] 1 AC 410 but not in Alcock v. Chief Constable of South Yorkshire Police [1992] 1 AC 310 . Proximity clearly existed in the present case. Further, it was clearly reasonably foreseeable that the plaintiff might suffer physical injury in the accident, though in the event he did not. The question is whether or not the plaintiff was required to prove that it was reasonably foreseeable that he would suffer such nervous shock as was capable of leading to some identifiable illness.The decided cases reveal several observations indicating that this question is to be answered in the affirmative.

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In King v. Phillips [1953] 1 Q.B. 429. 441 Denning L.J.. said:
"Howsoever that may be, whether the exemption for shock be based on want of duty or on remoteness, there can be no doubt since Bourhill v. Young [1943] AC 92 that the test of liability for shock is foreseeability of injury by shock."
That statement was endorsed by Viscount Simonds in The Wagon Mound (No. 1) [1961] AC 388 , 426.In Mount Isa Mines Ltd. v. Pusey (1970) 125 C.L.R. 383, 402 Windeyer J. said:
"In what way does one test whether a particular harm is of the genus that was foreseeable? We have at least one 'fixed and definite line.' Liability for nervous shock depends on foreseeability of nervous shock. That, not some other form of harm, must have been a foreseeable result of the conduct complained of. The particular pathological condition which the shock produced need not have been foreseeable. It is enough that it is a 'recognisable psychiatric illness.'"
In Jaensch v. Coffey (1984) 54 A.L.R. 417, 452 Deane J. said, referring to Bourhill v. Young [1943] A.C. 97:"One finds in the judgments an implicit (explicit in the case of Lord Porter, at p. 119) acceptance of a refinement of the ordinary test of reasonable foreseeability of injury which has subsequently received general acceptance: in the case of mere psychiatric injury, the requirement of reasonable foreseeability will not be satisfied unless injury in that particular form, as distinct from personal injury generally . . . was reasonably foreseeable." (Deane J.'s underlining)Later, he said, at p. 460:
"The limitations upon the ordinary test of reasonable foreseeability in cases of mere psychiatric injury are conveniently stated in negative form. Two of them have already been mentioned. The first of those is that reasonable foreseeability of risk of personal injury generally will not suffice to give rise to a duty of care to avoid psychiatric injury unassociated with conventional physical injury: a duty of care will not arise unless risk of injury in that particular form was reasonably foreseeable."
In The Wagon Mound (No. 2) [1967] 1 AC 617 , 636. Lord Reid stated as a general proposition applicable to cases based on negligence:

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"It has now been established by The Wagon Mound (No. 1) [1961] AC 388 and by Hughes v. Lord Advocate [1963] AC 837 that in such cases damages can only be recovered if the injury complained of was not only caused by the alleged negligence but was also an injury of a class or character foreseeable as a possible result of it."
That general proposition is valid in principle both as regards persons directly involved in an accident who claim on grounds of nervous shock and as regards those who claim as secondary victims. Reasonable foreseeability being the test, there is no logical ground for distinguishing between the two classes of claimants.A considerable amount of argument ranged over the question whether in applying the test of reasonable foreseeability in cases of nervous shock matters fell to be considered prospectively or ex post facto. In Bourhill v. Young [1943] AC 92 , 110, Lord Wright said:
"It is here, as elsewhere, a question of what the hypothetical reasonable man, viewing the position, I suppose ex post facto, would say it was proper to foresee."
In McLoughlin v. O'Brian [1983] AC 410 Lord Wilberforce spoke to similar effect at p. 420, and Lord Bridge of Harwich at p. 432. I think that what these judges had in mind was that it is necessary to look at the circumstances as they actually occurred and consider whether the hypothetical reasonable man, when directing his mind to the act or omission which is called in question, would have foreseen those circumstances, including that some person in the position of the plaintiff might as a result of what happened suffer nervous shock leading to an identifiable illness. Lord Wilberforce, at p. 422 in McLoughlin v. O'Brian mentioned that one of the factors in the light of which the claim had to be judged was the nature of the accident.Foreseeability of nervous shock is to be judged in the light of what would be suffered by a person of normal fortitude. In Bourhill v. Young Lord Wright said, at p. 110:
"What is now being considered is the question of liability, and this, I think, in a question whether there is a duty owing to members of the public who come within the ambit of the act, must generally depend on a normal standard of susceptibility."
Lord Porter said much the same thing at p. 117, and in McLoughlin v. O'Brian Lord Russell of Killowen said, at p. 429:

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"... the plaintiff is to be regarded as of normal disposition or phlegm: we are therefore not concerned to investigate the applicability of the 'thin skull' cases to this type of case."
I turn to apply the foregoing principles to the facts of the present case. The defendant can be liable only if the hypothetical reasonable man in his position should have foreseen that the plaintiff, regarded as a person of normal fortitude, might suffer nervous shock leading to an identifiable illness. For this purpose the nature of the accident is to be taken into account. The collision which occurred between the two cars is described by the trial judge as one of "moderate severity." No one involved sustained any bodily injury whatever. The plaintiff was able to drive his car home after the accident, though the damage to the car was such that owing to its age it was not economic to repair it, so that it was written off. The trial judge also said that the collision "must have been a frightening experience for Mr. Page and I have no doubt that he did suffer nervous shock in the broad sense of the word." These are inferences by the trial judge from the fact that a collision of moderate severity occurred. The plaintiff himself gave no evidence to the effect that he was at all frightened or shaken up. He did, however, give evidence that some three hours after the accident he began to suffer symptoms indicative of a recrudescence of CFS. Whether this recrudescence was attributable to the accident is debatable. Ralph Gibson L.J., after a careful review of the evidence, took the view that it was not. But assuming that it was, this can only be on account of the plaintiff's peculiar susceptibility. In my opinion a reasonable man in the position of the defendant would not have foreseen that an accident of the nature that he actually brought about might inflict on a person of normal susceptibility such mental trauma as to result in illness. There is no question of the plaintiff having been terrified by his experience, as the plaintiff foreseeably was in Dulieu v. White [1901] 2 K.B. 669, or having suffered an "acute emotional trauma," to use the expression of Lord Bridge of Harwich in Mcloughlin v. O'Brian [1983] AC 410 . 433.My Lords,for these reasons I would dismiss this appeal.

LORD ACKNER

My Lords,I have had the advantage of reading in draft the speech of my noble and learned friend Lord Lloyd of Berwick. I agree with it and for the reasons he gives I too would allow this appeal and make the order he proposes.As regards Mr. McKay Q.C.'s alternative submission, namely, that if it was necessary to establish foreseeability of injury by nervous shock in a person of normal fortitude, then the Court of Appeal were wrong to hold that

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such injury was not foreseeable, I should like to add the following observation:Assuming in favour of the respondent that the circumstances of the accident were such that:

The risk of injury by nervous shock was remote; and

Such a risk, although a possibility would become an actuality only in very exceptional circumstances.Nevertheless, the risk could not be said to be so farfetched or fantastic as to be ". . .a mere possibility which would never occur to the mind of a reasonable man" (per Lord Dunedin in Fardon v. Harcourt-Rivington (1932) 146 L.T. 391, 392). The risk was a real risk in the sense that it was justifiable not to take steps to eliminate it only if the circumstances were such that a reasonable man, careful of the safety of his neighbours, would think it right to neglect it. A reasonable man would only neglect such a risk if he had some valid reason for doing so, e.g. if it would involve considerable expense to eliminate the risk. He would weigh the risk against the difficulty of eliminating it. (See Wagon Mound (No. 2) [1967] 1 AC 617 per Lord Reid, at pp. 640-642, where for the reasons which have already been explained, the evidence led was substantially different from the evidence led in Wagon Mound (No. 1)). Of course, there was no justification whatsoever for the respondent suddenly and without warning driving across the path of the appellant, thereby making what must have been a frightening collision inevitable.The risk of injury by nervous shock was clearly foreseeable. A person of "normal fortitude," whatever that imprecise phrase may mean, could well have been terrified by the event and the resultant assault on his or her nervous system could well have caused a post-traumatic neurosis of one kind or another. That it would have been as serious and as long lasting, as occurred in this case, is accepted by the respondent to be nothing to the point.

LORD JAUNCEY OF TULLICHETTLE

My Lords,The primary issue in this appeal is whether in a case of injury resulting solely from nervous shock a plaintiff must show that injury of such a type was foreseeable or whether it is sufficient to show that any personal injury was foreseeable. By nervous shock, I mean such an impact upon the mind or nervous system as is recognised by modern medical science as capable of causing physical or psychiatric illness. The ordinary emotions of anxiety,

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fear, grief or transient shock are not conditions for which the law gives compensation.The appellant accepts that in what may be described as bystander cases where there is no direct impact upon the plaintiff it is necessary to establish the foreseeability of nervous shock. However he maintains that in participant cases, where there is direct involvement of the plaintiff in the negligent act, such foreseeability need not be established. It suffices that any personal injury may be foreseen. Much stress was laid by the appellant upon the distinction between participant and bystander and it is therefore appropriate to consider whether it is supported by principle or authority. When a plaintiff suffers damage as a result of the negligent act of another he must establish foreseeability of the general type of damage before he can succeed. The fact that personal injury is a likely consequence will not support a claim for pure economic loss. In the normal personal injury case arising from a factory or road accident the foreseeability of such injury arising from the negligent act seldom requires to be addressed since it is self evident from the circumstances. However that is not to say that the need for it is dispensed with. It is by no means impossible that a plaintiff could be directly involved in an accident caused by a negligent act where the circumstances required specific proof that injury was foreseeable. In Overseas Tankship (U.K.) Ltd v. Morts Dock & Engineering Co. Ltd. (The Wagon Mound) [1961] AC 388 the judgment of the Board contained the following observations, at p.426:
"Their Lordships conclude this part of the case with some general observations. They have been concerned primarily to displace the proposition that unforeseeability is irrelevant if damage is 'direct'. In doing so they have inevitably insisted that the essential factor in determining liability is whether the damage is of such a kind as the reasonable man should have foreseen. This accords with the general view thus stated by Lord Atkin in Donoghue v. Stevenson [1932] A.C. 562, 580:
'The liability for negligence, whether you style it such or treat it as in other systems as a "species of-culpa," is no doubt based upon a general public sentiment of moral wrongdoing for which the offender must pay.'
It is a departure from this sovereign principle if liability is made to depend solely on the damage being the 'direct' or 'natural' consequence of the precedent act. Who knows or can be assumed to know all the processes of nature?"If therefore a plaintiff who is directly involved in an accident requires to establish that the physical injuries sustained by him were the foreseeable consequences of a negligent act it is not easy to see in principle why such a plaintiff who suffers merely nervous shock and its consequences should not require to prove that it was similarly foreseeable. As a matter of common sense physical injuries are far more likely to result from an impact accident than is nervous shock causing subsequent illness. While it is not uncommon for a severe physical injury to give rise to some degree of psychiatric illness it is not the law that such illness is presumed to be a foreseeable consequence

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of every physical injury, rather does each case depend on its own circumstances. If therefore the foreseeability of psychiatric illness consequent upon physical injury requires to be established independently of the foreseeability of the physical injury why should the position be different where there was at the most a risk of physical injury which never eventuated?I turn to consider some of the authorities. In Bourhill v. Young [1943] A.C. 92 an Edinburgh fish wife sought damages from the executor of a deceased motorcyclist whose negligence caused him to collide with a motor car on the side of a tramcar opposite to that beside which the pursuer was standing. She did not, and indeed could not, see the collision but heard the noise and was frightened thereby although she had no reasonable fear of injury to herself. This House rejected her claim for nervous shock and consequential physical injuries on the ground that the motorcyclist owed her no duty since the reasonable hypothetical observer could not have foreseen that placed as she was the pursuer could have been affected by the accident in the manner in which she was. In short it was not foreseeable that she would suffer nervous shock. This lack of foreseeability went not to remoteness of damage but to the existence of a duty as was pointed out by Lord Russell of Killowen in the following passage at p. 101:
"In considering whether a person owes to another a duty a breach of which will render him liable to that other in damages for negligence, it is material to consider what the defendant ought to have contemplated as a reasonable man. This consideration may play a double role. It is relevant in cases of admitted negligence (where the duty and breach are admitted) to the question of remoteness of damage, i.e., to the question of compensation not to culpability, but it is also relevant in testing the existence of a duty as the foundation of the alleged negligence, i.e.. to the question of culpability not to compensation."
Bourhill v. Young was followed in King v. Phillips [1953] 1 Q.B. 429 where a mother saw a taxi some 70 yards away reverse towards and run apparently over her small son whom she heard scream. He was in fact only slightly hurt. Denning L.J. after dismissing the concept of there being two different torts, namely one where physical injury is foreseeable and another where emotional injury is foreseeable concluded that the only consequences for which a tortfeasor was excused were those which were too remote. He continued, at p.441:
"Howsoever that may be, whether the exemption for shock be based on want of duty or on remoteness, there can be no doubt since Bourhill v. Young [1943] AC 92 that the test of liability for shock is foreseeability of injury by shock."

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This passage was referred to with approval in the following passage in the judgment of the Board in The Wagon Mound (No. 1) [1961] AC 388 . at p.426:
"We have come back to the plain common sense stated by Lord Russell of Killowen in Bourhill v. Young [1943] AC 92 , 101. As Denning LJ. said in King v. Phillips [1953] 1 Q.B. 429, 441 'there can be no doubt since Bourhill v. Young that the test of liability for shock is foreseeability of injury by shock. ' Their Lordships substitute the word Tire' for 'shock' and endorse this statement of the law."
The plain common sense stated by Lord Russell of Killowen is to be found in the passage at p. 101 to which I have already referred. In McLoughlin v. O'Brian [1983] AC 410 , although the appellant (plaintiff), accepted that the agreed test for liability for shock was the foreseeability thereof Lord Bridge of Harwich said, at p. 432:
"The judges, in all the decisions we have been referred to, have assumed that it lay within their own competence to determine whether the plaintiff's 'nervous shock' (as lawyers quaintly persist in calling it) was in any given circumstances a sufficiently foreseeable consequence of the defendant's act of omission relied on as negligent to bring the plaintiff within the scope of those to whom the defendant owed a duty of care."
He later stated, at p.433:
"The question, then, for your Lordships' decision is whether the law, as a matter of policy, draws a line which exempts from liability a defendant whose negligent act or omission was actually and foreseeably the cause of the plaintiff's psychiatric illness and, if so, where that line is to be drawn."
It was argued that Denning L.J. had misunderstood the reasoning in Bourhill v. Young [1943] AC 92 and that his error had been perpetuated in later cases. I do not consider that this criticism is justified. In both King v. Phillips [1953] 1 Q.B. 429 and in Bourhill v. Young the only injury relied upon by the plaintiff was that resulting from nervous shock. The pursuer failed in Bourhill v. Young because it was held that the motor-cyclist could not reasonably have foreseen that she would suffer nervous shock as a result of his negligent driving. The factual position in King v. Phillips was broadly similar and it seems to me that Denning L.J. was doing no more than recognise that where the only injury complained of results from nervous shock foreseeability of such shock must be established before a breach of duty can arise.

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My Lords,as is so often the case in the field of negligence valuable contributions to the discussion are to be found in judgments of the High Court of Australia and in the context of this appeal I propose to refer to two. In Mount Isa Mines Ltd v. Pusey (1970) 125 C.L.R. 383 two electricians in a power house were horribly burnt following an explosion and an electric arc of intense heat. The plaintiff who was working on a lower floor heard the noise, immediately went to investigate and helped one of the two electricians down to an ambulance. He later developed a serious mental disturbance. The High Court, in holding the defendant liable, accepted that the test of liability for shock was foreseeability of injury by shock. Windeyer J., after referring to a passage in the judgment of Dixon J. in an earlier case in The High Court of Australia said, at p. 395:
"This passage is noteworthy: first, as an anticipation of the present- day rule that a cause of action for nervous shock depends on foreseeability of harm 'of some such nature' as that which actually occurred. Secondly, it emphasises that nervous shock cases are not a new tort: they turn simply on the circumstances in which damages are recoverable for a particular kind of harm caused by a tort."
He said, at p. 402:
"In what way does one test whether a particular harm is of the genus that was foreseeable? We have at least one 'fixed and definite line'. Liability for nervous shock depends on foreseeability of nervous shock. That, not some other form of harm, must have been a foreseeable result of the conduct complained of. The particular pathological condition which the shock produced need not have been foreseeable. It is enough that it is a 'recognizable psychiatric illness'."
Walsh J. said, at p.413:
"One must ask also whether or not the finding that 'shock and some form of mental illness or neurosis' was foreseeable satisfies the requirements of the principle asserted in The Wagon Mound (No.l) [1961] AC 388 , 426 that 'the essential factor in determining liability is whether the damage is of such a kind as the reasonable man should have foreseen'. In the application of this principle there may be difficulty in some cases in determining whether damage for which an action is brought and damage which was foreseeable are the same 'kind' of damage. But in the present case there are two reasons which appear to me to justify the conclusion reached by Skerman J. The first is that it is not a condition of liability that either the precise character of the damage or the extent of it should have been foreseen. It is necessary only that the damage suffered should not be different in kind from that which was foreseeable: see Hughes v. Lord Advocate [19631] A.C. 837, 845 and Chapman v. Hearse (1961) 106 C.L.R. 112, 121. The second reason is that in The Wagon Mound (No 1) [1961] A.C.

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388. 426 express approval was given to the statement of Denning L.J. in King v. Phillips [1953] 1 Q.B. 429, 441 that 'there can be no doubt since Bourhill v. Young [1943] AC 92 that the test of liability for shock is foreseeability of injury by shock'. Thus injury by shock is treated as a distinct 'kind' or class of damage for the purposes of the general principle enunciated in The Wagon Mound (No.1) [1961] A.C. 388 that liability depends upon the foreseeability of the kind of damage for which the defendant is sued."In Jaensch v. Coffey (1984) 54 A.L.R. 417 The High Court held that it was reasonably foreseeable that a wife who visited her seriously injured husband in hospital would suffer shock inducing a psychiatric illness. Brennan J. after a detailed consideration of authorities including Bourhill v. Young, the two Wagon Mound cases Mount Isa Mines Ltd v. Pusey and McLoughlin v. O'Brian said, at p.430:
"In cases of negligence occasioning nervous shock, as in cases of negligence occasioning physical injury the 'essential factor in determining liability is whether the damage is of such a kind as the reasonable man should have foreseen' (The Wagon Mound (No 1) [1961] AC 388 , 426). The distinction in principle between the two classes of cases, however, depends on the kind of damage that the reasonable man should foresee. Where a plaintiff is entitled to damages for negligence occasioning nervous shock, some recognizable psychiatric illness induced by shock must be reasonably foreseeable."
Deane J. expressed views to a similar effect, at p.460:
"The limitations upon the ordinary test of reasonable foreseeability in cases of mere psychiatric injury are conveniently stated in negative form. Two of them have already been mentioned. The first of those is that reasonably foreseeability of risk of personal injury generally will not suffice to give rise to a duty of care to avoid psychiatric injury unassociated with conventional physical injury: a duty of care will not arise unless risk of injury in that particular form was reasonably foreseeable."
In the USA Tobriner J. delivering the judgment of the Supreme Court of California in Dillon v. Legg (1968) 69 Cal. Reptr. 72 also refers to the fact that the law of tort holds a defendant liable only for injuries to others which to the defendant at the time were reasonably foreseeable, and he continued later, at p.80:
"This foreseeable risk may be of two types. The first class involves actual physical impact. A second type of risk applies to the instant situation. 'In other cases, however, plaintiff is outside the zone of physical risk '(or there is no risk of physical impact at all), but bodily

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injury or sickness is brought on by emotional disturbance which in turn is caused by defendant's conduct. Under general principles recovery should be had in such a case if defendant should foresee fright or shock severe enough to cause substantial injury in a person normally constituted'. . . (2 Harper & Jones, The Law of Torts (1956) at 1035- 1036)."It was urged upon your Lordships that all these cases involved bystanders as opposed to participants and that they were therefore not relevant to the present appeal where the appellant was directly involved in the collision. I reject this submission for two reasons. In the first place in none of the judgments was it suggested that the need to prove foreseeability of nervous shock was other than a general requirement applicable to all cases where damages therefor were claimed. Indeed Wagon Mound (No 1) was a case of direct damage by fire, comparable to a participant case, but the judgment nevertheless applied to it the dictum of Denning L.J. to which I have already referred, in King v. Phillips, albeit substituting "fire" for "shock". In the second place foreseeability of injury is necessary to determine whether a duty is owed to the victim. Unless such injury can be foreseen the victim is not a neighbour within the celebrated dictum of Lord Atkin in Donoghue v. Stevenson [1932] A.C.562 and cannot recover. A victim therefore has to establish neighbourhood whether he is a participant in the negligent act or merely a bystander and there can be justification neither in law nor in logic for departing from the general principles expressed in Donoghue v. Stevenson. I have no doubt that the Court of Appeal were correct to conclude that the appellant could only succeed if he could demonstrate that nervous shock giving rise to some form of psychiatric illness was a foreseeable consequence of the respondent's negligence.The appellant relied strongly on a passage in the speech of Lord Oliver of Aylmerton in Alcock v. Chief Constable of South Yorkshire [1992] 1 A.C. 310, 406F - H. After referring to the fact that compensable injury may be caused just as much by a direct assault upon the nervous system as by direct physical contact with the body Lord Oliver continued, at p. 407A:
"Cases in which damages are claimed for directly inflicted injuries of this nature may present greater difficulties of proof but they are not, in their essential elements, any different from cases where the damages claimed arise from direct physical injury and they present no very difficult problems of analysis where the plaintiff has himself been directly involved in the accident from which the injury is said to arise. 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."

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Lord Oliver then went on to remark that cases of "liability for nervous shock broadly divided into two categories:"
"... that is to say, those cases in which the injured plaintiff was involved, either mediately or immediately, as a participant, and those in which the plaintiff was no more than the passive and unwilling witness of injury caused to others. In the context of the instant appeals the cases of the former type are not particularly helpful, except to the extent that they yield a number of illuminating dicta, for they illustrate only a directness of relationship (and thus a duty) which is almost self- evident from a mere recital of the facts."
It was argued that these passages supported the contention that foreseeability of nervous shock was not necessary in a direct participation case. I do not agree. Lord Oliver was considering proximity as determinative of the existence of a duty of care and drawing a distinction between a victim directly involved in an accident and one who merely witnessed it. He certainly was not saying that a victim directly involved in an accident did not require to prove the foreseeability of the nervous shock from which he suffered as a result thereof.The appellant argued that if foreseeability of nervous shock was required to be proved by a participant, the assumption of reasonable fortitude, which applied in the case of a bystander, did not apply to him but rather that the respondent tortfeasor must take his victim as he found him. The rule that a tortfeasor is entitled to assume that his victim is of normal fortitude is designed to limit the class of bystanders to whom a duty is owed and is neither relevant nor necessary in the case of participants. Taking your victim as you find him however is relevant, not to the existence of a duty owed to him but rather to the question of damages payable in respect of breach of a duty otherwise established. So far as the fortitude rule is concerned it is necessary to look at a number of authorities.In Wilkinson v. Downton [1897] 2 QB 57 the defendant informed the plaintiff that her husband had been smashed up in an accident sustaining two broken legs. This was quite untrue and apparently intended as a practical joke. The plaintiff however received a severe shock producing serious physical consequences. Wright J. after concluding that the defendant had wilfully done an act calculated to cause physical harm said, at p.59:
"One question is whether the defendant's act was so plainly calculated to produce some effect of the kind which was produced that an intention to produce it ought to be imputed to the defendant, regard being had to the fact that the effect was produced on a person proved to be in an ordinary state of health and mind. I think that it was."

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I take from this passage that the judge thought it appropriate to apply the foreseeability test in the context of a person of normal susceptibility to such an act. In Bourhill v. Young [1943] AC 92 , 110 Lord Wright said:
"What is now being considered is the question of liability, and this. I think, in a question whether there is duty owing to members of the public who come within the ambit of the act, must generally depend on a normal standard of susceptibility."
A few sentences later he said:
"What danger of particular infirmity that would include must depend on all the circumstances, but generally, I think, a reasonably normal condition, if medical evidence is capable of defining it, would be the standard. The test of the plaintiff's extraordinary susceptibility, if unknown to the defendant, would in effect make him an insurer."
Lord Porter said, at p. 117:
"The driver of a car or vehicle, even though careless, is entitled to assume that the ordinary frequenter of the streets has sufficient fortitude to endure such incidents as may from time to time be expected to occur in them, including the noise of a collision and the sight of injury to others, and is not to be considered negligent towards one who does not possess the customary phlegm."
In McLoughlin v. O'Brian [1983] AC 410 , 422 Lord Wilberforce referred to the assumption that ordinary bystanders be possessed of fortitude sufficient to enable them to endure the calamities of modern life and Lord Bridge of Harwich (p.436) considered that the above quoted dictum of Lord Porter in Bourhill v. Young was as acceptable in 1982 as it was in 1942. I consider that it is still acceptable in 1995. In Jaensch v. Coffey 54 A.L.R. 417 Brennan J. said, at p. 431:
"Moreover, it is generally recognized that what will induce a psychiatric illness in one person may leave another unaffected. Some people are naturally more robust - or less sensitive - than others. Yet reasonable foreseeability is an objective criterion of duty, and a general standard of susceptibility must be postulated. At least to that extent it is possible to confine consideration of the question whether it is reasonably foreseeable that the perception of a particular phenomenon might induce in the plaintiff a psychiatric illness. Some general guidelines apply. The first guideline is this: the question 'whether there is duty owing to members of the public who come within the ambit of the act, must generally depend on a normal standard of susceptibility.' (per Lord Wright in Bourhill v. Young [1943] A.C. at p. 110)"

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None of these cases involved participants but the observations of Lord Wright and Brennan J. were stated in fairly broad terms and were not specifically confined to bystander cases. That there appear to have been no similar expressions of opinion in relation to participants is, perhaps, hardly surprising since cases such as the present where a participant sustains no immediate physical injuries must be rare. However there do not appear to be reasons in principle or logic for drawing a distinction between the two classes of person. To take a simple example suppose A while slowly reversing his car into a tight parking space inadvertently bumps the car of B which is stationary, B, who is a woman prone to hysteria, promptly develops that condition with consequential physical injury. The circumstances are such that no normal person would have been in any way mentally or physically affected by the bump. Is B to be compensated because A should have foreseen that a hysterical woman might be in the car and thereby sustain a shock from a minor bump? Commonsense would loudly say No and in my view the law should and does likewise. I am satisfied that in determining whether a tortfeasor should have foreseen that either a participant or a bystander would suffer nervous shock as a result of his negligent act the proper test is to assume that the victim is of reasonable fortitude and susceptibility unless, of course, the tortfeasor has special knowledge of the victim's unusual condition.In applying this test in the present appeal consideration must be given to the precise circumstances in which foresight is to be exercised. The appellant maintained that the respondent should have applied his mind to the position immediately before the impact without regard to the consequences thereof while the respondent submitted that what had actually occurred must be taken into account. Support for the respondent's contention is to be found in Bourhill v. Young [1943] AC 92 , 110 where Lord Wright said:
"It is here, as elsewhere, a question of what the hypothetical reasonable man, viewing the position, I suppose ex post facto, would say it was proper to foresee."
In McLoughlin v. O'Brian [1983] AC 410 , 420 Lord Wilberforce after referring to Lord Atkin's celebrated dictum in Donoghue v. Stevenson continued:
"This is saying that foreseeability must be accompanied and limited by the law's judgment as to persons who ought, according to its standards of value or justice, to have been in contemplation. Foreseeability, which involves a hypothetical person, looking with hindsight at an event which has occurred, is a formula adopted by English law, not merely for defining, but also for limiting, the persons to whom duty may be owed, and the consequences for which an actor may be held responsible."
This statement, following as it did immediately after the reference to Donoghue v. Stevenson, was clearly intended to apply to foreseeability in

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negligence generally and not only to cases involving nervous shock to a bystander. Lord Bridge of Harwich said, at p. 432:
"Then, here comes the all-important question. Given the fact of the plaintiffs psychiatric illness caused by the defendant's negligence in killing or physically injuring another, was the chain of causation from the one event to the other, considered ex post facto in the light of all that has happened, 'reasonably foreseeable' by the 'reasonable man'?"
Although Lord Bridge posed the question in the context of psychiatric illness suffered by a bystander he said nothing to suggest that ex post facto consideration was peculiar to such a situation.The appellant's argument was that if the respondent had considered the matter immediately before impact he should have foreseen that a serious accident was likely to occur. The difficulty about this argument is that it appears to ignore reality. The question ceases to be whether it is foreseeable that a reasonably robust person would have suffered psychiatric illness as a result of what actually happened and becomes instead whether it is foreseeable that such a person would have suffered psychiatric illness as a result of what might have happened but did not in fact do so. In this context I cannot do better than quote the following words of Windeyer J. in Mount Isa Mines Ltd v. Pusey 125 C.L.R. 383. 401:
"... the suggestion that because the plaintiff could have had damages if he had suffered a different kind of harm he can now have damages for the harm he actually suffered calls to mind the 'imaginary necktie' and Professor Goodhart's vigorous comments."
My Lords I have no hesitation in adopting the approach of Lord Wilberforce (supra) and in concluding that foreseeability whether of danger or of injury likely to be suffered necessarily involves consideration of events as they have actually occurred.Against this background I now turn to consider whether it was foreseeable that the appellant would have suffered some nervous shock with consequential physical injury as a result of this accident. In all the reported cases in which a plaintiff has recovered damages for nervous shock the causative event has been of a dramatic and horrifying nature. In Dulieu v. White & Sons [1901] 2 KB 669 the plaintiff was assumed to have reasonable apprehension of immediate bodily hurt when the pair-horse van was driven into the bar where she was working. In Hambrook v. Stokes Brothers. [1925] 1 K.B. 141 the plaintiff saw a run-away lorry heading in the direction of her children and then discovered that it had injured one of them. In Attia v. British Gas Plc [1988] 1 Q.B. 304 a woman saw her house and all her possessions therein go up in flames. In McLoughlin v. O'Brian [1983] A.C. 410 a mother found her injured husband and children in a terrible state in

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hospital. In that case Lord Bridge of Harwich pointed out. at p.433. that the legal profession well understood that acute emotional trauma could well cause a psychiatric illness. In Chadwick v. British Railways Board [1967] 1 W.L.R. 912 a volunteer rescuer at the scene of the Lewisham railway disaster witnessed horrific scenes during the course of his heroic work. In Mount Isa Mines Ltd v. Pusey 125 C.L.R. 383 the rescuer was faced with a horrifying sight of his horribly burnt work mate and in Jaensch v. Coffey 54 A.L.R. 417 a wife saw her husband after an accident in circumstances in which it was thought that he would not survive. There can be little doubt that in all these cases the plaintiff suffered the acute emotional trauma referred to by Lord Bridge of Harwich (supra). In marked contrast was the unreported Court of Appeal case of Nicholls v. Rushton (unreported) 29 april 1992: Court of Appeal (Civil Division) Transcript No. 0401 of 1992 in which the plaintiff had been driving a car involved in a collision. As in this appeal she suffered no physical injury and was able to drive away after the accident. She sought damages for severe shock and shaking up but her claim was dismissed by the Court of Appeal.On no view could it here be suggested that the appellant suffered an acute emotional trauma. Otton J. found that the collision was one of moderate severity. However neither the plaintiff nor the occupants of the other car were injured. The appellant suffered no bruises from his seat belt and did not suggest that he was at any time in fear for his own safety or that of the occupants of the other car. He was able to write down the name and address of the respondent, to telephone his wife quite normally and then drive home. His car sustained damage which resulted in it being written off by his insurers but it appears that it was on the ground of economics due to its age and small value rather than because of the severity of the damage. This case is accordingly far removed from those cases in which foreseeability of nervous shock has been established. A motor car collision in which the only damage is to the vehicles involved neither of which even leave the road is not an event which could normally be expected to produce nervous shock with consequential psychiatric illness to one or more of the occupants. I entirely agree with the views of Ralph Gibson and Hoffmann L.JJ. in the Court of Appeal [1994] 4 All E.R. 522, at pp. 544g and 552h - 553c respectively to the effect that it was not reasonably foreseeable that the appellant would suffer nervous shock as a result of this accident. The appeal must therefore be dismissed.

LORD BROWNE-WILKINSON

My Lords,I have had the advantage of reading in draft the speech prepared by my noble and learned friend Lord Lloyd of Berwick. I too would allow the

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appeal for the reasons which he gives. As your Lordships are not agreed in the result and we are differing from the conclusions reached by the Court of Appeal, I propose to add a few words of my own.In my view this case is bedeviled by the use of the description "nervous shock" to describe any injury suffered otherwise than by a chain of demonstrably physical causes. The law has long recognised tangible physical damage to the body of the plaintiff as a head of damage. Medical science has now advanced so far that the process whereby an impact causing direct physical injury to one limb or organ of the body can be demonstrated to have caused consequential physical damage to another limb or organ. Lawyers can readily accept that such consequential, physical damage is the consequence of the original impact. Hence there is a willingness to accept that all such tangible physical damage is foreseeable.Medical science has also demonstrated that there are other injuries the body can suffer as a consequence of an accident, such injuries not being demonstrably attributable directly to physical injury to the plaintiff. Injuries of this type may take two forms. First, physical illness or injury not brought about by a chain of demonstrable physical events but by mental or emotional stresses i.e. by a psychiatric route. Examples are a heart attack or a miscarriage produced by shock. In this case, the end product is a physical condition although it has been brought about by a process which is not demonstrably a physical one but lies in the mental or nervous system. The second form is psychiatric illness itself which is brought about by mental or emotional stresses i.e. by a psychiatric route. Because medical science has so far been less successful in demonstrating the nature of psychiatric illness and the processes whereby it is brought about by the psychiatric route, the courts have been more reluctant to accept the risk of such illness as being foreseeable. But since the decision of this House in McLoughlin v. O'Brian [1983] AC 410 it has been established that, in certain circumstances, a defendant can be liable for illness or injury, whether psychiatric or physical, produced in a plaintiff by purely psychiatric processes, without any direct physical impact on, or injury to, the limbs or organs of the plaintiff. That case also establishes that such a process is, in certain circumstances, to be treated as foreseeable by a defendant.It follows that in the present case the fact that the plaintiff suffered no tangible physical injury is irrelevant to the question whether or not he is entitled to recover damages for the recrudescence of his illness. On the judge's findings, the plaintiff suffered injury (the recrudescence of his illness) by the psychiatric route i.e. by reason of shock exacerbating his condition. The question, therefore, is whether a driver of a car should reasonably foresee that a person involved in an accident may suffer psychiatric injury of some kind (whether or not accompanied by physical injury). I have no doubt that he should. It is not physical injury alone which causes illness or injury: physical or psychiatric illness occurs quite apart from physical injury. Thus in Dulieu v. White and Sons [1901] 2 KB 669 the pregnant plaintiff behind

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the bar received no physical injury when the defendant's pair-horse van arrived in the bar from the highway. Her only allegation was that the nervous shock caused her to give birth prematurely i.e. she alleged physical injury by the psychiatric route. It was held that she was entitled to recover: nobody has since suggested that the case was not rightly decided.In Currie v. Wardrop 1927 S.C. 538 the plaintiff was walking arm in arm with her fiancé when they were both knocked down by a bus. The fiancé was badly injured but the plaintiff suffered no physical injury. She claimed damages for shock, such shock being in part due to fear for herself and in part to fear for her fiancé. The issue was whether the jury's award of damages for shock due to her fear for herself "aggravated by anxiety for the safety of her companion" could stand, the law of Scotland at that date not allowing damages for shock caused by anxiety for others. Although the Court of Session was divided on whether the award could stand, all the members were of one mind that the pursuer was entitled to damages for nervous shock caused by her fear for her own safety. See also Brown v. Glasgow Corporation 1922 S.C. 527. A consultation paper (No. 137 of 1995) entitled Liability for psychiatric illness issued by the Law Commission since the conclusion of the argument before your Lordships contains material showing that psychiatric illness is a frequent consequence of involvement in a road accident and that participants in a traumatic event are more likely to suffer such illness than those who merely witness or hear of it: see particularly paragraphs 3.11 and 3.13.The law has therefore been established both in England and Scotland for many years that a plaintiff who is a participant in an accident is entitled to recover damages for shock even though he or she has not suffered any tangible physical injury. I can see no good reason to modify this law. The analogy drawn with the more recent development in the law permitting a plaintiff, not a participant in an accident, to recover damages for nervous shock flowing from fear for the safety of others or from the trauma of witnessing the event does not seem to me to touch on the case. A non- participant plaintiff is outside the ordinary area within which the defendant can foresee causing damage. The only method whereby a non participant plaintiff can establish that the defendant should have foreseen damage to the plaintiff is by showing that he ought to have foreseen nervous shock. As Lord Lloyd of Berwick has demonstrated, the law as laid down in relation to these non- participant claims for nervous shock damages has not been applied to claims for such damages made by a plaintiff who was himself involved in the accident. In this connection, it is noteworthy that in Bourhill v. Young [1943] A.C. 92, 120 Lord Porter, whilst dismissing the pursuer's claim in that case, referred to Currie v. Wardrop 1927 S.C. 538 and said "Undoubtedly, there was in that case a duty to the pursuer (the woman) and a breach of that duty ..." It is clear that Lord Porter at least was drawing a distinction between claims for nervous shock made by a participant in the accident on the one hand and by a non-participant on the other.

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I am therefore of opinion that any driver of a car should reasonably foresee that, if he drives carelessly, he will be liable to cause injury, either physical or psychiatric or both, to other users of the highway who become involved in an accident. Therefore he owes to such persons a duty of care to avoid such injury. In the present case the defendant could not foresee the exact type of psychiatric damage in fact suffered by the plaintiff who, due to his M.E., was "an eggshell personality". But that is of no significance since the defendant did owe a duty of care to prevent foreseeable damage, including psychiatric damage. Once such duty of care is established, the defendant must take the plaintiff as he finds him.Finally I would endorse Lord Lloyd's remarks about the dangers of the court seeking to draw hard and fast lines between physical illness and its causes on the one hand and psychiatric illness and its causes on the other. Although medical science has not as yet progressed very far in elucidating the processes whereby psychiatric disorders come about, recent developments suggest a much closer relationship between physical and mental processes than had previously been thought. There is a substantial body of informed medical opinion which attributes some mental illness to physical causes such as chemical or hormonal imbalance. In the present case, for example, although all but one of the distinguished doctors who gave evidence were agreed that there was indeed an illness (however mysterious) called M.E. and that the plaintiff suffered from it, they had differing views as to its causes. One thought M.E. was linked to viral infection (physical) and stress (psychological): another to neuroendocrine disturbance (physical) and psychiatric disorder. In cases where distinguished doctors take differing views as to the aetiology of an illness it obviously presents great problems for the court to resolve what was the cause of the recrudescence of such an illness. For the courts to impose different criteria for liability depending upon whether the injury is "physical" or "psychiatric" is likely to lead to a growing complication in straight forward personal injury cases. In my judgment, the law will be more effective if it accepts that the result of being involved in a collision may include both physical and psychiatric damage.I would therefore allow the appeal and remit the issue of causation (if not agreed) to the Court of Appeal for its determination.

LORD LLOYD OF BERWICK

My Lords,IntroductionThis is the fourth occasion on which the House has been called on to consider "nervous shock". On the three previous occasions, Bourhill v. Young

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[1943] AC 92 , McLoughlin v. O'Brian [1983] AC 410 and Alcock v. Chief Constable of South Yorkshire Police [1992] 1 AC 310 , the plaintiffs were, in each case, outside the range of foreseeable physical injury. Thus, in Bourhill v. Young the plaintiff was "not in any way physically involved in the collision": see per Lord Russell of Killowen, at p. 101. The defendant's motor cycle was already some 45 feet past the plaintiff when he collided with a motor car, and was killed. The plaintiff was on the far side of a tramcar, and so shielded from the physical consequences of the accident. If, therefore, liability was to be established, it could only be on the basis that the defendant should have foreseen injury by nervous shock. The plaintiff did, in fact, suffer injury to her health as a result of the shock which she sustained. But as the defendant could not reasonably foresee that she would suffer injury by shock, it was held that she could not recover.Likewise, in McLoughlin v. O'Brian, the plaintiff was at home two miles away when her husband and three children were involved in a road accident. When she reached the hospital about two hours later, she heard that her daughter had been killed and saw the extent of her son's injuries. The shock which she suffered resulted in psychiatric illness. It was held by this House, reversing the Court of Appeal and the trial judge, that the plaintiff could recover damages, since it was reasonably foreseeable that, unlike Mrs. Bourhill, she would suffer nervous shock as a result of injuries to her family.Alcock v. Chief Constable of South Yorkshire Police was the case arising out of the disaster at the Hillsborough football stadium. A number of plaintiffs brought actions for damages for nervous shock. Two of the plaintiffs were present at the stadium. Others saw the disaster on television. They all failed either because the relationship between the plaintiffs and the victims was not sufficiently close, or because watching the scene on television did not create the necessary degree of proximity.In all these cases the plaintiff was the secondary victim of the defendant's negligence. He or she was in the position of a spectator or bystander. In the present case, by contrast, the plaintiff was a participant. He was himself directly involved in the accident, and well within the range of foreseeable physical injury. He was the primary victim. This is thus the first occasion on which your Lordships have had to decide whether, in such a case, the foreseeability of physical injury is enough to enable the plaintiff to recover damages for nervous shock.The factual distinction between primary and secondary victims of an accident is obvious and of long-standing. It was recognised by Lord Russell of Killowen in Bourhill v. Young, when he pointed out that Mrs. Bourhill was not physically involved in the collision. In Alcock's case [1992] 1 AC 310 Lord Keith of Kinkel said, at p. 396, that in the type of case which was then before the House, injury by psychiatric illness "is a secondary sort of injury brought about by the infliction of physical injury, or the risk of physical

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injury, upon another person." In the same case. Lord Oliver of Aylmerton said, at p. 407, of cases in which damages are claimed for nervous shock:
"Broadly they divide into two categories, that is to say, those cases in which the injured plaintiff was involved, either mediately, or immediately, as a participant, and those in which the plaintiff was no more than the passive and unwilling witness of injury caused to others."
Later in the same speech, at pp. 410-411, he referred to those who are involved in an accident as the primary victims, and to those who are not directly involved, but who suffer from what they see or hear, as the secondary victims. This is, in my opinion, the most convenient and appropriate terminology.Though the distinction between primary and secondary victims is a factual one, it has, as will be seen, important legal consequences. So the classification of all nervous shock cases under the same head may be misleading. In Alcock's case Lord Oliver said, at p. 407:
"It is customary to classify cases in which damages are claimed for injury occasioned in this way under a single generic label as cases of 'liability for nervous shock'. This may be convenient but in fact the label is misleading if and to the extent that it is assumed to lead to a conclusion that they have more in common than the fact of similarity of the medium through which the injury is sustained - that of an assault upon the nervous system of the plaintiff through witnessing or taking part in an event - and that they will, on account of this factor, provide a single common test for the circumstances which give rise to a duty of care."
It is of cardinal importance in the present case to bear that warning in mind.Although the plaintiff was, as I have said, the primary victim, the peculiarity of the present case is that, by good fortune, he suffered no broken bones and no bruising; indeed he had no external physical injury of any kind. But as a direct result of the accident he suffered a recrudescence of an illness or condition known variously as M.E., C.F.S. or P.V.F.S., from which he had previously suffered in a mild form on sporadic occasions, but which, since the accident, has become an illness of "chronic intensity and permanency".

The Facts

The facts, as found by the judge, are that the plaintiff, a schoolteacher by profession, was driving at approximately 30 miles per hour when suddenly, without warning, the defendant, coming in the opposition direction, turned right across the white line. The plaintiff braked hard, but the two vehicles

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were so close that he could not avoid a collision. The impact was severe enough to cause considerable damage to both vehicles. Nevertheless, the plaintiff was able to drive his car home.

The judge said:

"I find on the balance of probabilities that there was a collision of moderate severity. It must have been a frightening experience for Mr. Page and I have no doubt that he did suffer nervous shock in the broad sense of the word."
Three hours later the plaintiff felt exhausted. He took to his bed. The exhaustion continued. The plaintiff has never fully recovered, and has not worked since.The judge heard a great deal of medical evidence over many days as to whether an illness or condition known as M.E. exists at all. and if so how it is caused, whether the plaintiff was suffering from the illness before the accident, and whether and to what extent his present condition is attributable to the accident.Having heard all this evidence, the judge made the tindings to which I have already briefly referred. In particular, he found that, despite scepticism on the part of some of the doctors, and it may be members of the public, M.E. is a genuine illness. He specifically rejected any suggestion that the plaintiff is guilty of malingering or hysteria.

The correct approach

Against that factual background, the judge dealt with the law quite shortly. He referred to Malcolm v. Broadhurst [1970] 3 A.E.R. 508, a decision of Geoffrey Lane J. In that case, a woman suffered head injuries in a car accident, as a result of which a pre-existing nervous disturbance was exacerbated. Geoffrey Lane J. said, at p. 511:
"The defendant must take the wife as he finds her and there is no difference in principle between an egg-shell skull and an egg-shell personality: Love v. Port of London Authority [1959] 2 Lloyd's Rep. 541. Exacerbation of her nervous depression was a readily foreseeable consequence of injuring her ... I do not derive any assistance from the 'nervous shock' cases; they are concerned with the effect of the sudden traumatic effect of witnessing or hearing of an accident and their somewhat special rules do not seem to me to be applicable to the present circumstances."
Otton J. adopted the same line of reasoning.
"Once it is established that C.F.S. exists and that a relapse or recrudescence can be triggered by the trauma of an accident and that nervous shock was suffered by the plaintiff who is actually involved

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in the accident, it becomes a foreseeable consequence. The nervous shock cases relied on by Mr. Priest, in my judgment, have no relevance. The plaintiff was not a spectator of the accident who suffered shock from what he witnessed happening to another. He was directly involved and suffered the shock directly on experiencing the accident. The remoteness argument, therefore, must be rejected."Since physical injury to the plaintiff was clearly foreseeable, although it did not in the event occur, the judge did not consider, as a separate question, whether the defendant should have foreseen injury by nervous shock.When the case got to the Court of Appeal [1994] 4 All E.R. 522, the approach became more complicated. Mr. Priest's argument, as summarised by Ralph Gibson L.J., at p. 540, was follows:
"If a plaintiff establishes that he has suffered some physical injury, he may advance a claim in respect of a recognised psychiatric illness which has resulted from that physical injury. If a plaintiff has suffered no physical injury, and his only injuries are a recognised form of psychiatric illness, he may succeed if the court decides that psychiatric illness was foreseeable in the case of a person of reasonable fortitude. There is no difference in this respect, it was submitted, between a bystander and a person directly involved in an event, except that the consequences are more likely to be foreseeable in the case of the latter than in the case of the former."
The Court of Appeal accepted Mr. Priest's argument. "The fact", said Ralph Gibson L.J., at p. 544, "that this plaintiff was directly involved does not, in my judgment, render irrelevant the question whether injury by nervous shock was reasonably foreseeable as a result of what happened to him in the accident." The Lord Justice went on hold that injury by nervous shock was not foreseeable in a person of ordinary fortitude as a result of what happened to the plaintiff. In reaching this conclusion he was much influenced, as is apparent from his judgment, by the fact that the plaintiff suffered no physical injury.Hoffmann L.J. (p. 549) put the point with his usual epigrammatic force. In cases of nervous shock, he said, "foreseeability of physical injury is neither necessary nor sufficient". I agree that it is not necessary, as Hambrook v. Stokes Brothers. [1925] 1 K.B. 141, McLoughlin v. O'Brian [1983] AC 410 and numerous other cases show. But is it not sufficient? Hoffmann L.J. considered that if one part of his apophthegm was true, the other must also be true. But I am not sure that this follows.If as in Malcolm v. Broadhurst [1970] 3 All E.R. 508, the plaintiff had suffered a head injury or a broken leg, or significant bruising, with consequential psychiatric illness, it is very doubtful whether the case would ever have reached the Court of Appeal at all. It would be like many other

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personal injury cases which are tried or settled every day in the High Court and the County Courts. Of course, it would have been necessary to prove that the psychiatric illness was genuine, arid that it was caused by the accident. But nobody would have stopped to consider the foreseeability of nervous stock. Nobody would have referred to Bourhill v. Young [1943] AC 92 . We now know that the plaintiff escaped without external injury. Can it be the law that this makes all the difference? Can it be the law that the fortuitous absence of foreseeable physical injury means that a different test has to be applied? Is it to become necessary, in ordinary personal injury claims, where the plaintiff is the primary victim, for the court to concern itself with different "kinds" of injury?Suppose, in the present case, the plaintiff had been accompanied by his wife, just recovering from a depressive illness, and that she had suffered a cracked rib, followed by an onset of psychiatric illness. Clearly, she would have recovered damages, including damages for her illness, since it is conceded that the defendant owed the occupants of the car a duty not to cause physical harm. Why should it be necessary to ask a different question, or apply a different test, in the case of the plaintiff? Why should it make any difference that the physical illness that the plaintiff undoubtedly suffered as a result of the accident operated through the medium of the mind, or of the nervous system, without physical injury? If he had suffered a heart attack, it cannot be doubted that he would have recovered damages for pain and suffering, even though he suffered no broken bones. It would have been no answer that he had a weak heart.I must say at once that I prefer the simplicity of the judge's approach to what, with respect, seems to be an unnecessary complication introduced by the Court of Appeal. Foreseeability of psychiatric injury remains a crucial ingredient when the plaintiff is the secondary victim, for the very reason that the secondary victim is almost always outside the area of physical impact, and therefore outside the range of foreseeable physical injury. But where the plaintiff is the primary victim of the defendant's negligence, the nervous shock cases, by which I mean the cases following on from Bourhill v. Young, are not in point. Since the defendant was admittedly under a duty of care not to cause the plaintiff foreseeable physical injury, it was unnecessary to ask whether he was under a separate duty of care not to cause foreseeable psychiatric injury.Apart from its simplicity, Otton J.'s approach has other attractions. As medical science advances, it is important that the law should not be seen to limp too far behind: see Mount Isa Mines Ltd. v. Pusey (1970) 125 C.L.R. 383 per Windeyer J. at 395. As long ago as 1901 the courts were already beginning to become aware that there may be no hard and fast line between physical and psychiatric injury, such as had hitherto been supposed. In Dulieu v. White & Sons [1901] 2 KB 669 , Kennedy J. said, at p. 677:

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"For my own part, I should not like to assume it to be scientifically true that a nervous shock which causes serious bodily illness is not actually accompanied by physical injury, although it may be impossible, or at least difficult, to detect the injury at the time in the living subject. I should not be surprised if the surgeon or the physiologist told us that nervous shock is or may be in itself an injurious affection of the physical organism."
In Bourhill v. Young [1943] AC 92 Lord Macmillan said, at p. 103:
"The crude view that the law should take cognisance only of physical injury resulting from actual impact has been discarded, and it is now well recognised that an action will lie for injury by shock sustained through the medium of the eye or ear without direct contact. The distinction between mental shock and bodily injury was never a scientific one, for mental shock is presumably in all cases the result of, or at least accompanied by, some physical disturbance in the sufferer's system. And a mental shock may have consequences more serious than those resulting from physical impact."
Likewise, in more recent times, Lord Bridge of Harwich drew attention to the inter-relation of physical and psychiatric injury in McLoughlin v. O'Brian [19831 AC 410 , 433:
"No judge who has spent any length of time trying personal injury claims in recent years would doubt that physical injuries can give rise not only to organic but also to psychiatric disorders. The sufferings of the patient from the latter are no less real and frequently no less painful and disabling than from the former. Likewise, I would suppose that the legal profession well understands that an acute emotional trauma, like a physical trauma, can well cause a psychiatric illness in a wide range of circumstances and in a wide range of individuals whom it would be wrong to regard as having any abnormal psychological make-up. It is in comparatively recent times that these insights have come to be generally accepted by the judiciary. It is only by giving effect to these insights in the developing law of negligence that we can do justice to an important, though no doubt small, class of plaintiffs whose genuine psychiatric illnesses are caused by negligent defendants."
In an age when medical knowledge is expanding fast, and psychiatric knowledge with it, it would not be sensible to commit the law to a distinction between physical and psychiatric injury, which may already seem somewhat artificial, and may soon be altogether outmoded. Nothing will be gained by treating them as different "kinds" of personal injury, so as to require the application of different tests in law.

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My noble and learned friend Lord Keith of Kinkel has drawn attention to an observation of Lord Wright in Bourhill v. Young [1943] AC 92 , 110, that in nervous shock cases the circumstances of the accident or event must be viewed ex post facto. There are similar observations by Lord Wilberforce and Lord Bridge in McLoughlin v. O'Brian [1983] AC 410 , at pp. 420 and 432. This makes sense, as Lord Keith points out, where the plaintiff is a secondary victim. For if you do not know the outcome of the accident or event, it is impossible to say whether the defendant should have foreseen injury by shock. It is necessary to take account of what happened in order to apply the test of reasonable foreseeability at all. But it makes no sense in the case of a primary victim. Liability for physical injury depends on what was reasonably foreseeable by the defendant before the event. It could not be right that a negligent defendant should escape liability for psychiatric injury just because, though serious physical injury was foreseeable, it did not in fact transpire. Such a result in the case of a primary victim is neither necessary, logical nor just. To introduce hindsight into the trial of an ordinary running- down action would do the law no service.Are there any disadvantages in taking the simple approach adopted by Otton J.? It may be said that it would open the door too wide, and encourage bogus claims. As for opening the door, this is a very important consideration in claims by secondary victims. It is for this reason that the courts have, as a matter of policy, rightly insisted on a number of control mechanisms. Otherwise, a negligent defendant might find himself being made liable to all the world. Thus in the case of secondary victims, foreseeability of injury by shock is not enough. The law also requires a degree of proximity: see Alcock's case [1992] 1 AC 310 per Lord Keith of Kinkel at p. 396, and the illuminating judgment of Stuart-Smith L.J. in McFarlane v. E.E. Caledonia Ltd. [1994] 2 All ER 1 , 14. This means not only proximity to the event in time and space, but also proximity of relationship between the primary victim and the secondary victim. A further control mechanism is that the secondary victim will only recover damages for nervous shock if the defendant should have foreseen injury by shock to a person of normal fortitude or "ordinary phlegm".None of these mechanisms are required in the case of a primary victim. Since liability depends on foreseeability of physical injury, there could be no question of the defendant finding himself liable to all the world. Proximity of relationship cannot arise, and proximity in time and space goes without saying.Nor in the case of a primary victim is it appropriate to ask whether he is a person of "ordinary phlegm". In the case of physical injury there is no such requirement. The negligent defendant, or more usually his insurer, takes his victim as he finds him. The same should apply in the case of psychiatric injury. There is no difference in principle, as Geoffrey Lane J. pointed out in Malcolm v. Broadhurst [1970] 3 All E.R. 508. between an eggshell skull and an eggshell personality. Since the number of potential claimants is limited

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by the nature of the case, there is no need to impose any further limit by reference to a person of ordinary phlegm. Nor can I see any justification for doing so.As for bogus claims, it is sometimes said that if the law were such as I believe it to be, the plaintiff would be able to recover damages for a fright. This is not so. Shock by itself is not the subject of compensation, any more than fear or grief or any other human emotion occasioned by the defendant's negligent conduct. It is only when shock is followed by recognisable psychiatric illness that the defendant may be held liable.There is another limiting factor. Before a defendant can be held liable for psychiatric injury suffered by a primary victim, he must at least have foreseen the risk of physical injury. So that if, to take the example given by my noble and learned friend Lord Jauncey of Tullichettle, the defendant bumped his neighbour's car while parking in the street, in circumstances in which he could not reasonably foresee that the occupant would suffer any physical injury at all, or suffer injury so trivial as not to found an action in ton. there could be no question of his being held liable for the onset of hysteria. Since he could not reasonably foresee any injury, physical or psychiatric, he would owe the plaintiff no duty of care. That example is. however, very far removed from the present.So I do not foresee any great increase in unmeritorious claims. The court will, as ever, have to be vigilant to discern genuine shock resulting in recognised psychiatric illness. But there is nothing new in that. The floodgates argument has made regular appearances in this field, ever since it first appeared in Victorian Railways Commissioners v. Coultas (1888) 13 App. Cas. 222. I do not regard it as a serious obstacle here.My provisional conclusion, therefore, is that Otton J.'s approach was correct. The test in every case ought to be whether the defendant can reasonably foresee that his conduct will expose the plaintiff to risk of personal injury. If so, then he comes under a duty of care to that plaintiff. If a working definition of "personal injury" is needed, it can be found in section 38(1) of the Limitation Act 1980:'"Personal injuries' includes any disease and any impairment of a person's physical or mental condition ..."There are numerous other statutory definitions to the same effect. In the case of a secondary victim, the question will usually turn on whether the foreseeable injury is psychiatric, for the reasons already explained. In the case of a primary victim the question will almost always turn on whether the foreseeable injury is physical. But it is the same test in both cases, with different applications. There is no justification for regarding physical and psychiatric injury as different "kinds" of injury. Once it is established that the defendant is under a duty of care to avoid causing personal injury to the

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plaintiff, it matters not whether the injury in fact sustained is physical, psychiatric or both. The utility of a single test is most apparent in those cases such as Schneider v. Eisovitch [1962] Q.B. 430, Malcolm v. Broadhurst [1970] 3 All E.R. 508 and Brice v. Brown [1984] 1 All E.R. 997, where the plaintiff is both primary and secondary victim of the same accident.Applying that test in the present case, it was enough to ask whether the defendant should have reasonably foreseen that the plaintiff might suffer physical injury as a result of the defendant's negligence, so as to bring him within the range of the defendant's duty of care. It was unnecessary to ask, as a separate question, whether the defendant should reasonably have foreseen injury by shock; and it is irrelevant that the plaintiff did not, in fact, suffer any external physical injury.

The authorities

I turn now to the authorities to see if there is anything which supports the contrary view taken by the Court of Appeal. All the dicta which appear to support the contrary view are to be found in cases where the plaintiff was the secondary victim, and they almost all go back to an observation of Denning L.J. in King v. Phillips [1953] 1 Q.B. 429, 441, an observation which has been very frequently repeated, but has often, I suspect, been misunderstood.Before coming to King v. Phillips, however, it is first necessary to look at Victorian Railways Commissioners v. Coultas (1888) 13 App Cas 222 and Dulieu v. White & Sons [1901] 2 KB 669 .In the former case, the defendant's servant permitted the plaintiff to drive across a level crossing in her buggy, when a train was approaching. There was no actual impact, but a very near miss. The plaintiff suffered severe nervous shock, which in turn produced illness and a miscarriage. She recovered damages for negligence at first instance, but the decision was reversed by the Privy Council, on the ground that the damage was too remote. The decision has long since been disapproved. Today there can be no doubt that the plaintiff would have kept her damages, but not, I suggest, because the defendant's gatekeeper should have foreseen injury by shock, but on the straightforward ground that he should have foreseen that a collision might result in the plaintiff's injury or death.In Dulieu v. White & Sons, the Divisional Court declined to follow Victorian Railways Commissioners v. Coultas, preferring instead to follow two decisions of the Irish Courts. The facts of that case were that the defendant's horse-van was driven so negligently that it ended up in a public house where the plaintiff was serving behind the bar. She suffered no impact, but according to her statement of claim the shock resulted in serious illness, and the premature birth of her child. It was held that the statement of claim

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disclosed a good cause of action. In the course of his judgment Kennedy J. suggested that recovery for nervous shock should be limited to cases in which the plaintiff fears for his own safety. He said, at p. 675:
"The shock, where it operates through the mind, must be a shock which arises from a reasonable fear of immediate personal injury to oneself."
It is now clear that this proposed limitation was too restrictive. But it has never, until now, been suggested that the decision depended in any way on foreseeability of injury by shock, as distinct from the ordinary duty of care owed to lawful users of the highway.In Hambrook v. Stokes Brothers [1925] 1 K.B. 141, the Court of Appeal by a majority disapproved Kennedy J.'s dictum in Dulieu v. White. It was held that the plaintiff was entitled to recover damages under the Fatal Accidents Act for the death of his wife, resulting from nervous shock. Her shock was caused by fear, not for her own safety, but for her children's safety, not her own. She was thus the secondary victim of the defendant's negligence. It went without saying that if the shock had been brought about by fear for her own safety, she would have recovered. Thus, Bankes L.J. said, at p. 151:
"Upon the authorities as they stand, the defendant ought to have anticipated that if his lorry ran away down this narrow street, it might terrify some woman to such an extent, through fear of some immediate bodily injury to herself, that she would receive such a mental shock as would injure her health."
Atkin L. J. said, at p. 158:
"In my opinion it is not necessary to treat this cause of action as based upon a duty to take reasonable care to avoid administering a shock to wayfarers. The cause of action, as I have said, appears to be created by breach of the ordinary duty to take reasonable care to avoid inflicting personal injuries, followed by damage, even though the type of damage may be unexpected - namely, shock. The questions appears to be as to the extent of the duty, and not as to remoteness of damage."
After considering another way of putting the matter, Atkin L.J. added, at p. 159:
"It may be, however, that there is not any practical difference between the two ways of putting it; for the degree of care to be exercised by the owner of the vehicle would still in practice be measured by the standard of care necessary to avoid the ordinary form of personal injuries."

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Sargant L.J. dissented. He would not have extended liability for nervous shock beyond the area covered by Kennedy J. 's dictum, that is to say, cases where the plaintiff fears for his own safety. But that is the very area with which we are concerned in the present case. The following passage, at pp. 161-162, is thus directly relevant:
"It is no doubt more difficult to prove that physical injury results from nervous shock than from direct impact. But when once this difficulty of proof is overcome, I cannot see why a negligence which so nearly causes direct impact as to cause physical injury by nervous shock is a more remote or less natural cause of damage than a negligence causing actual physical impact. Or, to put it more precisely, as a matter of duty which is owed to the plaintiff, and the neglect of which has caused damage, the duty of the defendant so to control his vehicle as to avoid causing physical injury to those on or near the highway, including the plaintiff, can hardly be limited to actual physical impact on the plaintiff (though this is in fact the result of the American cases), but must logically include such an immediate threat of impact on the plaintiff as to produce physical injury to him, or her. through the nervous system. There seems to me to be no magic in actual personal contact. A threatened contact producing physical results should be an equivalent."
There is no support in any of the judgments for the view that where the plaintiff is the primary victim of the defendant's negligence, liability for nervous shock depends on the foreseeability of injury by nervous shock.I now come to King v. Phillips [1953] 1 Q.B. 429, the case of the "unimaginative taxi cab driver", as it was called by Professor A. L. Goodhart in (1953) 69 L.Q.R. 347. In the course of backing his taxi without looking, the defendant injured a small boy, and damaged his tricycle. His mother was at a window, about 80 yards away, when she heard a scream. She saw the taxi backing slowly onto the tricycle, but she could not see her son. She suffered severe shock. She brought an action on behalf of her son as the primary victim, and also on her own behalf. McNair J. found in favour of the son. He was awarded £5. for his personal injuries and £10. for his tricycle. But the mother's action failed, and her appeal was dismissed.It seems clear enough that the result nowadays would have been different. In particular, the ground on which Denning L.J. decided the case, namely, that because the taxi was backing so slowly, the damage was too remote, is indefensible. Professor Goodhart's caustic comment seems well justified. But the leading judgment given by Singleton L.J. is instructive. After referring to Bourhill v. Young, he said, at p. 437:
"I find it difficult to draw a distinction between damages from physical injury and damage from shock; prima facie, one would think that, if a driver should reasonably have foreseen either, and damage resulted

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from the one or from the other, the plaintiff would be entitled to succeed."

Denning L.J. agreed. He said, at p. 439:
"I cannot see why the duty of a driver should differ according to the nature of the injury. ... If he drives negligently with the result that a bystander is injured, then his breach of duty is the same, no matter whether the injury is a wound or is emotional shock. Only the damage is different."
Denning L.J. refused to accept any distinction between physical and emotional injury. Otherwise, he said, one would be driven to the view that there are two different torts, one tort when the defendant can foresee physical injury, and another tort when he can foresee emotional injury. This could not be right. He said, at p. 440:
"There is one wrong only, the wrong of negligence. I know that damage to person and damage to property are for historical reasons regarded as different torts; but that does not apply to physical injury and emotional injury."
So far. there is nothing which assists the defendant's case. Indeed, the passage from Singleton L.J.'s judgment is strongly against him. But then comes Denning L.J.'s celebrated dictum at p. 441:
"Howsoever that may be, whether the exemption for shock be based on want of duty or on remoteness, there can be no doubts that since Bourhill v. Young [1943] AC 92 that the test for liability for shock is foreseeability of injury by shock."
The danger of any good phrase is that it gets repeated so often and applied so uncritically that in the end it tends to distort the law. Denning L.J.'s dictum is wrong in two respects. It is both too wide and too narrow. It is too wide where the plaintiff is the secondary victim, as she was in King v. Phillips. For subsequent cases have shown that foreseeability of injury by shock is not the sole test: (see Alcock's case [1992] 1 AC 310 , 396 per Lord Keith of Kinkel and McFarlane v. E.E. Caledonia Ltd. [1994] 2 All ER 1 ) The test is also too narrow, where, as here, the plaintiff is the primary victim. There is nothing in Bourhill v. Young to displace the ordinary rule that where the plaintiff is within the range of foreseeable physical injury the defendant must take his victim as he finds him. The whole point of Bourhill v. Young was that the plaintiff was not within the range of foreseeable physical injury. She was not "involved" in the collision. There was, therefore, no way in which she could recover damages unless she could show that the defendant ought to have foreseen injury by shock. It is only in that limited sense that it was ever true to say that liability for shock depends on foreseeability of injury by

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shock. The dictum has no application where the plaintiff is the primary victim of the defendant's negligence.Mr. Priest relied heavily on two cases decided by the High Court of Australia. In the first, Mount Isa Mines Ltd. v. Pusey 125 C.L.R. 383, the plaintiff went to the rescue of two fellow employees who had been severely burnt by an electrical short circuit. One of them died the next day. The plaintiff went on working without any apparent ill consequences. Then about four weeks later he developed a psychiatric illness described as severe schizophrenic reaction. The court had no difficulty in holding that the defendant should have foreseen that a fellow employee might come to the rescue, and might suffer psychiatric damage. The point in the case, as appears from the argument at p. 385, and the judgment of Barwick C.J., at p. 388 and p. 390, turned on the finding of the trial judge that the "specific psychological reaction" was not foreseeable. It was held by the High Court that this was irrelevant. It was enough that the class of injury as distinct from the particular injury was foreseeable. The observation of Windeyer J., at p. 402, to which Lord Keith of Kinkel has referred, must be read in this light. The purpose of referring to psychiatric injury as a class was not to draw a line between psychiatric injury on the one hand and physical injury on the other; but to include within the psychiatric class all forms of psychiatric injury however rare and unforeseen. It follows that the case does not touch in any way on the issue in the present case. This is abundantly clear from a passage in Walsh J.'s judgment at p. 414. Having cited Denning L.J.'s dictum, he continued:
"It is not here necessary to consider whether or not there are satisfactory reasons for treating injury by shock as different in kind from other forms of personal injury. If all personal injuries whether "mental" or "physical" were to be treated as being of the same kind then it would be evident in the present case that damage of a foreseeable kind was suffered. But for the purposes of the present case the statement in The Wagon Mound (No. 7) [1961] AC 388 , 426 that the test of liability for shock is foreseeability of injury by shock may be accepted."
The facts of the second Australian case, Jaensch v. Coffey 54 A.L.R. 417 were very similar to those in McLoughlin v. O'Brian. The plaintiff suffered severe anxiety and depression after seeing her husband in hospital, shortly after he had been severely injured in a car accident. The High Court upheld her claim for damages. The only point of interest in the decision, as appears from the leading judgment of Gibbs C.J. is that the plaintiff was "exceptionally pre-disposed" to anxiety and depression. Otherwise, all the case called for was a straightforward application of the principles already well established in Mount Isa Mines Ltd. v. Pusey and McLoughlin v. O'Brian. The facts came nowhere near the present case. However, in the course of a very lengthy judgment Deane J. made a number of observations, two of which

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are quoted by Hoffmann L.J. in the Court of Appeal in the present case. He said, at p. 452:
"One finds in the judgments [in Bourhill v. Young] an implicit (explicit in the case of Lord Porter, at p. 119) acceptance of a refinement of the ordinary test of foreseeability of injury which has subsequently received general acceptance; in the case of mere psychiatric injury, the requirement of reasonable foreseeability will not be satisfied unless injury in that particular form, as distinct from personal injury generally (cf. per Atkin L.J. Hambrook v. Stokes at pp. 157-8 and per Singleton L.J. King v. Phillips at p. 437), was reasonably foreseeable ..."
With great respect, this seems to be a misunderstanding of what Lord Porter said in Bourhill v. Young [1943] AC 92 . The case was fought on the basis (as Deane J. had just recognised) that the plaintiff was not in fear for her own personal safety. So she could not succeed by showing that she was within the range of foreseeable physical injury. She could only succeed by showing that she was within the range of foreseeable emotional injury. But this she failed to do. Bourhill v. Young does not represent a refinement of the ordinary test of reasonable foreseeability. It represents an extension of that test, as Lord Edmund-Davies pointed out in McLoughlin v. O'Brian [1983] AC 410 , 423- 424. He quoted in support of his view the laconic observation of Professor Goodhart in "The Shock Cases and Area of Risk" (1953) 16 M.L.R. 14, 16, note 10:
"The area of risk of physical injury may extend to only x yards, while the area of risk of emotional injury may extend to y yards."
The cases cited by Deane J. do not support the restrictive proposition that in cases of "mere psychiatric injury" (by which I understand him to mean cases not involving physical injury) the plaintiff's injury must be foreseeable "in that particular form as distinct from personal injury generally". On the contrary, Atkin L.J. in Hambrook v. Stokes Brothers and Singleton L.J. in King v. Phillips lend strong support to the opposite view.The second passage is at p. 460.
"The limitations upon the ordinary test of reasonable foreseeability in cases of mere psychiatric injury are conveniently stated in negative form. Two of them have already been mentioned. The first of those is that reasonable foreseeability of personal injury generally will not suffice to give rise to a duty of care to avoid psychiatric injury unassociated with conventional physical injury: a duty of care will not arise unless risk of injury in that particular form was reasonably foreseeable."

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This adds nothing to the earlier passage. For the reasons already stated, I do not regard it as a correct view of the law.I come last to what is, perhaps, the strongest authority supporting the view taken by the Court of Appeal: Overseas Tank Ship (U.K.) Ltd. v. Morts Dock Engineering Co. Ltd. (The Wagon Mound (No. 1)) [1961] AC 388 . This case, and the companion case of The Wagon Mound (No. 2) [1967] 1 A.C. 617, established that "the essential factor in determining liability is whether the damage is of such a kind as the reasonable man should have foreseen": see p. 426. The defendants allowed a large quantity of bunker oil to spill over in Sydney Harbour. The oil was ignited by welding operations of the employees of the plaintiff dock company. The Wagon Mound (No. 1) was presented on the basis, in which both parties joined, that fuel oil on water did not crease a forseeable fire risk. Had the plaintiff company done otherwise it would have been met with the defence of contributory negligence which in New South Wales then provided a complete defence. The defendants could, however, foresee that the oil would do some trivial damage to the plaintiffs slipway by fouling. The Supreme Court of New South Wales found in favour of the plaintiffs, applying the rule in In re Polemis and Furness Withy & Co. Ltd. [1921] 3 K.B. 560. The decision was overturned by the Privy Council. Viscount Simonds, in tendering the advice of the Privy Council, said that their Lordships had been concerned primarily to displace the proposition that unforeseeability is irrelevant if damage is "direct". But in the course of his judgment (p. 426), he cited by way of illustration the dictum of Denning L.J. in King v. Phillips [1953] 1 Q.B. 429, 441, and added:
"Their Lordships substitute the word 'fire' for 'shock' and endorse this statement of the law."
Viscount Simonds did not attempt to define what he meant by "kind of damage", and the concept is apt to be elusive, as Mr. R.W.M. Dias and Professor Jolowicz have pointed out in their comments in [1961] C.L.J. 23, 30. See also Clerk and Lindsell on Torts 16th ed. (1989), at pp. 587-588. It is clear that Viscount Simonds regarded shock as a "kind of damage". Otherwise, he would not have cited Denning L.J.'s dictum. But the case was not in any way concerned with liability for shock. The reference to Bourhill v. Young [1943] AC 92 , both in the argument and in the judgment, was for quite a different purpose, namely, to pray in aid the "plain common sense" stated by Lord Russell of Killowen, that foreseeability goes to compensation as well as culpability. I do not think the Privy Council was intending to indicate that Denning L.J.'s dictum applied across the board in personal injury actions, or that psychiatric injury is "a different kind of damage" from physical injury, for the purposes of establishing the relevant duty of care. Although the Privy Council in The Wagon Mound (No. 1) has often been regarded as having approved the full width of Denning L.J.'s dictum, I consider this goes too far. As I have said, I prefer to regard the reference to the dictum as being more by way of illustration. If so, then it does not stand in the way of a sensible and practical approach to cases where the plaintiff is

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the primary victim of the defendant's negligence, along the lines proposed by the judge.Many other cases were cited in argument, but I need only refer to one, Brice v. Brown [1984] 1 All E.R. 997. This was one of the authorities cited with approval by Hoffmann L.J. There can be no doubt that the case was correctly decided on the facts. It would have been a reproach to the law if the plaintiff had not been able to recover damages for the severe mental illness which she suffered as a result of the accident, partly out of fear for herself, and partly out of fear for her daughter. But as she was herself involved in the accident, and as the accident was quite severe (her daughter suffered quite serious injuries), she was plainly owed a duty of care by the defendant. In these circumstances it was, in my opinion, unnecessary to ask as a separate question whether the defendant should have foreseen injury by shock to a person of normally robust constitution. It sufficed that she was a primary victim of the defendant's negligence.I return to the facts of the present case to mention a fall-back argument on which Mr. McKay relied. Assuming, contrary to his primary argument, that it was necessary to establish foreseeability of injury by nervous shock in a person of normal fortitude, then the Court of Appeal were wrong to hold that such injury was not foreseeable. The judge held, as I have said, that the collision was one of moderate severity. He had no doubt that the plaintiff suffered nervous shock in the broad sense of that word. He concluded that since the plaintiff was actually involved in the accident, it became a foreseeable consequence.I have some difficulty in understanding how the Court of Appeal was justified in disturbing the judge's primary findings, or the inference which he drew from those findings. Ralph Gibson L.J. was impressed by the fact that the plaintiff suffered no physical injury. If he was using this piece of hindsight in order to qualify the judge's finding that the accident was one of moderate severity, then, with respect, he was wrong. If he was saying that a person of normal fortitude involved in an accident does not suffer shock, with recognised psychiatric consequences, unless he receives some physical injury, then I would disagree. As Lord Bridge of Harwich, said in McLoughlin v. O'Brian [1983] AC 410 , 433:
". . .an acute emotional trauma, like a physical trauma, can well cause a psychiatric illness in a wide range of circumstances and in a wide range of individuals whom it would be wrong to regard as having any abnormal psychological make-up."
When cars collide at 30 miles per hour, the possibility that those involved will suffer nervous shock, resulting in some form of psychiatric illness, is not something to be brushed aside. In my opinion, the Court of Appeal were wrong to find that psychiatric illness, in some form, was not a foreseeable

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consequence of the accident in a person of normal fortitude. But for reasons already mentioned, I do not regard that as the relevant test.In conclusion, the following propositions can be supported:In cases involving nervous shock, it is essential to distinguish between the primary victim and secondary victims;In claims by secondary victims the law insists on certain control mechanisms, in order as a matter of policy to limit the number of potential claimants. Thus, the defendant will not be liable unless psychiatric injury is foreseeable in a person of normal fortitude. These control mechanisms have no place where the plaintiff is the primary victim.In claims by secondary victims, it may be legitimate to use hindsight in order to be able to apply the test of reasonable foreseeability at all. Hindsight, however, has no part to play where the plaintiff is the primary victim.Subject to the above qualifications, the approach in all cases should be the same, namely, whether the defendant can reasonably foresee that his conduct will expose the plaintiff to the risk of personal injury, whether physical or psychiatric. If the answer is yes, then the duty of care is established, even though physical injury does not, in fact, occur. There is no justification for regarding physical and psychiatric injury as different "kinds of damage".A defendant who is under a duty of care to the plaintiff, whether as primary or secondary victim, is not liable for damages for nervous shock unless the shock results in some recognised psychiatric illness. It is no answer that the plaintiff was predisposed to psychiatric illness. Nor is it relevant that the illness takes a rare form or is of unusual severity. The defendant must take his victim as he finds him.These propositions do not, I think, involve any radical departure from the law as it was left by Kennedy J. in Dulieu v. White & Sons, and by the Court of Appeal in Hambrook v. Stokes Brothers [1925] 1 K.B. 141 and King v. Phillips [1953] 1 Q.B. 429, although the decision in the latter case can no longer be supported on its facts. In McLoughlin v. O'Brian [1983] AC 410 your Lordships had the opportunity to take the law forward by holding that the plaintiff could recover damages for nervous shock, even though she was two miles away at the time of the accident. No such opportunity offers in the present case. But it is at least as important that the law should not take a step backwards. This would, I fear, be the result if the decision of the Court of Appeal were allowed to stand.In the result, I would restore the judgment of Otton J., but subject to one last caveat. One of the grounds of appeal from Otton J.'s judgment was

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that his finding on causation was against the weight of the evidence. Ralph Gibson L.J. upheld this ground of appeal, but it was left open by Farquharson L.J. and Hoffmann L.J. Unless, therefore, the claim can now be settled, the case will have to go back to the Court of Appeal for a finding on this issue.I would allow the appeal and order that the respondents pay the appellants' costs in your Lordships' House. Costs before the judge and the Court of Appeal will have to wait the outcome of the issue on causation.

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