“Police officers must satisfy secondary victim tests to recover for psychiatric injury.”
Police officers attended the Hillsborough disaster and suffered psychiatric injury from witnessing the traumatic scenes. They claimed compensation for psychiatric harm, arguing their employment relationship created special circumstances.
Whether police officers who suffer psychiatric injury while on duty are entitled to more favourable treatment than ordinary secondary victims in negligence claims.
The House of Lords held that police officers must satisfy the same tests as other secondary victims. Most claims failed as the officers could not satisfy the proximity requirements.
This case clarified that professional rescuers receive no special treatment in psychiatric injury claims and must satisfy normal secondary victim tests. It represents important limitations on recovery for psychiatric harm in tort law.
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OSCOLA Citation
White v Chief Constable of South Yorkshire Police [1999] 2 AC 455 (HL)
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