alcock v chief constable of south yorkshire police judgment

alcock v chief constable of south yorkshire police judgment

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Two of the plaintiffs were spectators in the ground, but not in the pens where the disaster occurred, the remainder of the plaintiffs learned of the disaster through radio or television broadcasts. It is readily foreseeable that very real and easily ascertainable injury is likely to result to those dependent upon the primary victim or those upon whom, as a result of negligently inflicted injury, the primary victim himself becomes dependent. Lord Bridge propounded simply a criterion of the reasonable foreseeability by the defendant of the damage to the plaintiff which had occurred without necessarily invoking physical presence at or propinquity to the accident or its aftermath or any particular relationship to the primary victim as limiting factors, although, of course, clearly these elements would be important in the determination of what, on the facts of any given case, would be reasonably foreseeable. BENCH : Lord Keith of Kinkel, Lord Ackner, Lord Oliver of Aylmerton, Lord Jauncey of Tullichettle and Lord Lowry . In 2005, a duly qualified medical practitioner decided that K was disabled and that that was likely to be permanent. The defendant admitted that if he owed such a duty to any plaintiff, and if that plaintiff could show causation, then the defendant was in breach of duty and liable in damages to that plaintiff. Contains public sector information licensed under the Open Government Licence v3.0. My Lords, for these reasons I would dismiss each of these appeals. The cases varied between those present or not present at the scene, or those with close relatives present. 73, reversed on appeal [1992] 2 All E.R. It would, for instance, have made no difference to the result in Hambrook v. Stokes Brothers [1925] 1 K.B. The present position in relation to recognisable claims is that parents and spouses have been held entitled to recover for shock caused by fear for the safety of their children or the other spouse. The case was known as Frost and Others v Chief Constable of South Yorkshire Police and Others [1997] 1 All ER 540 in the lower courts. Alcock and Others v Chief Constable of South Yorkshire Police. In Jaensch v. Coffey (1984) 155 C.L.R. The plaintiffs, being relatives and friends of the deceased, inter alia suffered nervous shock having seen the events either from within the ground, or from outside or at home on . This case arose from the disaster … Psychiatric injury to him would not ordinarily, in my view, be within the range of reasonable foreseeability, but could not perhaps be entirely excluded from it if the circumstances of a catastrophe occurring very close to him were particularly horrific. The failure of the law in general to compensate for injuries sustained by persons unconnected with the event precipitated by a defendant's negligence must necessarily import the lack of any legal duty owed by the defendant to such persons. But such a causal link is assumed for the purposes of these appeals. Upon Report from the Appellate Committee to whom was referred the Cause Alcock and others against Wright (sued as Chief Constable of the South Yorkshire Police) and Copoc and others against Wright (sued as Chief Constable of the South Yorkshire Police), That the Committee had heard Counsel as well on Monday the 7th as on Tuesday the 8th, Wednesday the 9th, Thursday the 10th and … What constitutes the immediate aftermath of an accident must necessarily depend upon the surrounding circumstances. In Alcock v. Chief Constable of South Yorkshire Police [1992] 1 A.C. 310, claims were brought by those who had suffered psychiatric injury as a result of the Hillsborough disaster. I refer once again to a passage in the speech of Lord Wilberforce in McLoughlin v. O'Brian, at p. 422: Lord Wilberforce expressed the view, at p. 422H, that a "strict test of proximity by sight or hearing should be applied by all courts." I do not consider that it would be profitable to try and define who such others might be or to draw any dividing line between one degree of relationship and another. It was semi final of FA cup. Creating a unique profile web page containing interviews, posts, articles, as well as the cases you have appeared in, greatly enhances your digital presence on search engines such Google and Bing, resulting in increased client interest. However, the decades since the judgment have witnessed an explosion of new media platforms and technologies which have arguably transformed the dissemination of imagery. Packenham v Irish Ferries Limited [2004] In Alcock v. Chief Constable of South Yorkshire Police [1992] 1 AC 310, claims were brought by those who had suffered psychiatric injury as a result of the Hillsborough disaster. The algorithms of the law must keep pace with new and emerging technologies. change. Reasonable foreseeability is subject to controls. The leading speech was delivered by Lord Wilberforce. He was not, in my judgment, reasonably foreseeable as a potential sufferer from shock-induced psychiatric illness, in default of very special facts and none was established. In the first place a defendant could normally anticipate that in accordance with current television broadcasting guidelines shocking pictures of persons suffering and dying would not be transmitted. Alcock v Chief Constable of South Yorkshire Police concerned sixteen unsuccessful claims for psychiatric injury (PI) resulting from the Hillsborough disaster. 3. I, too, would therefore dismiss these appeals. The south Yorkshire police force that was responsible for crowd control at the match had negligently directed a large number of spectators to one end of the stadium into a caged pen as the result of which a fatal crash took place, succeeded by a stampede killing 95 people and physically injuring many others. Having set out, at pp. in Heaven v. Pender, 11 Q.B.D. Alcock v Chief Constable of South Yorkshire House of Lords. For example, in his illuminating judgment in Jaensch v. Coffey, (1984) 155 C.L.R. They were capable of giving rise to anxiety for the safety of relatives known or believed to be present in the area affected by the crush, and undoubtedly did so, but that is very different from seeing the fate of the relative or his condition shortly after the event. 141, para 5 Abramzik v. Brenner [(1967) 65 D.L.R. POLICE)(RESPONDENT) Lord TemplemanLord Bridge of HarwichLord GriffithsLord Goff of ChieveleyLord Browne-Wilkinson. Hill v Chief Constable of West Yorkshire [1987] UKHL 12, [1989] AC 53 was a judicial decision of the House of Lords in relation to the claim by the mother of Jacqueline Hill (one of the last victims of Peter Sutcliffe, the "Yorkshire Ripper") against West Yorkshire Police that their negligence in failing to apprehend the killer resulted in her daughter's death. (241(2017)DLT 319), Parliament’s Power To Legislate On The State Subject- Constitutional Provisions And Analysis, Malak Singh Etc v. State of Punjab & Haryana & Ors (1981) SCR (2) 311. E.P Royappa v. State of Tamil Nadu and Anr (AIR 1974 SC... Doctrine of Pleasure in the Indian Constitution, Paramount Surgimed Limited Versus Paramount Bed India Private Limited And Ors. The law has developed incrementally. So too in Best v. Samuel Fox & Co. Ltd. [1952] A.C. 716, 734, Lord Morton of Henryton observed: A fortiori the law will not compensate such a person for the mental anguish and even illness which may flow from having lost a wife, parent or child or from being compelled to look after an invalid, although there is a statutory exception to this where the victim dies as a result of the accident and the plaintiff is his widow or minor unmarried child. Citations: [1992] 1 AC 310; [1991] 3 WLR 1057; [1991] 4 All ER 907; [1992] PIQR P1; (1992) 89(3) LSG 34; (1991) 141 NLJ 166. The primary difficulty here was that of establishing the foreseeability of the injury which the plaintiff suffered rather than the proximity of her relationship to the defendant, who owed her the same duty as he owed to any other users of the highway. Citation of a principle so familiar may justly be described as trite but it is, I think, of critical importance in the context of the instant appeals. I assume that Mr. Harrison's relationship with his brothers was not an abnormal one. 439-443. On that day a football match was arranged to be played at the stadium between the Liverpool and the Nottingham Forest football clubs. The fact that the injury suffered is psychiatric and is caused by the impact on the mind of becoming involved in personal danger or in scenes of horror and destruction makes no difference. It was argued on their behalf that the law has never excluded strangers to the victim from claiming for nervous shock resulting from the accident. The overcrowding was due to police negligence. The quality of brotherly love is well known to differ widely - from Cain and Abel to David and Jonathan. Alcock v Chief Constable of South Yorkshire Police - Wikipedia They state, at pp. In the second place, a television programme such as that transmitted from Hillsborough involves cameras at different viewpoints showing scenes all of which no one individual would see, edited pictures and a commentary superimposed. To extend the notion of proximity in cases of immediately created nervous shock to this more elongated and, to some extent, retrospective process may seem a logical analogical development. My Lords, speaking for myself, I see no logic and no virtue in seeking to lay down as a matter of "policy" categories of relationship within which claims may succeed and without which they are doomed to failure in limine. Lord Oliver distinguished between primary and secondary victims to clarify the law and establish mechanisms to scrutinise secondary victims claims. The cases linked on your profile facilitate Casemine's artificial intelligence engine in recommending you to potential clients who might be interested in availing your services for similar matters. Get 2 points on providing a valid reason for the above No remoter relative has successfully claimed in the United Kingdom. Copoc and others (Appellants) v. Wright (sued as Chief, Constable of the South Yorkshire Police (Respondent), Alcock and others (Appellants) v. Wright (sued as Chief, Constable of the South Yorkshire Police) (Respondent). Course. Alcock v. Chief Constable of South Yorkshire Police (1991) 3 WLR 1057 Cases referrred Bourhill v. Young [1943 A.C. 92] para 5 McLoughlin v. O'Brian [(1983) 1 A.C. 410]. This chapter considers the landmark decision in Alcock v Chief Constable of South Yorkshire Police [1992] 1 AC 310 concerning liability for psychiatric injury, or ‘nervous shock’. by GILLIAN KELLY B.L. It must, as it seems to me, be attributable simply to the fact that such persons are not, in contemplation of law, in a relationship of sufficient proximity to or directness with the tortfeasor as to give rise to a duty of care, though no doubt "policy," if that is the right word, or perhaps more properly, the impracticability or unreasonableness of entertaining claims to the ultimate limits of the consequences of human activity, necessarily plays a part in the court's perception of what is sufficiently proximate. The Law of Torts (LAWS212) Academic year. PETITIONER: Alcock. 549, 583: Although it is a vital step towards the establishment of liability, the satisfaction of the test of reasonable foreseeability does not, in my judgment, ipso facto satisfy Lord Atkin's well known neighbourhood principle enuniciated in Donoghue v. Stevenson [1932] AC 562, 580. Alcock v Chief Constable of South Yorkshire Police [1992] 1 AC 310. POLICE)(RESPONDENT) Lord TemplemanLord Bridge of HarwichLord GriffithsLord Goff of ChieveleyLord Browne-Wilkinson. Contents 1 Facts The term Zimmediate victim [ is used to describe All were agreed that actually witnessing or being present at or near the scene of an accident was not essential to ground liability in an appropriate case, but that the duty might equally be owed to one who comes upon the immediate aftermath of the event. 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. Alcock and others v Chief Constable of the South Yorkshire Police CIVIL Alcock v Chief Constable of South Yorkshire Police [1991] Facts. There she was told that one of the children had been killed, and saw her husband and the other two in a distressed condition and bearing on their persons the immediate effects of the accident. He did not altogether close the door to an enlargement of the area of the possible duty but observed: In so far as this constituted an invitation to courts seized of similar problems in the future to draw lines determined by their perception of what public policy requires, it was an invitation accepted by Parker L.J. It is a useful illustration of the extreme difficulty of separating the compensatable injury arising from the presence of the plaintiff at the scene of an accident from the non-compensatable consequences flowing from the simple fact that the accident has occurred, but it is of little assistance otherwise, save for a hint in the judgment of Lord Denning M.R. But these are factual difficulties and I can see no logic and no policy reason for excluding claims by more remote relatives. They introduce the requirement of "proximity" as conditioning the duty of care. Equally obviously, the foreseeability of such injury to such a person will be more difficult to establish than similar injury to a spouse or parent of the primary victim. It is, however, trite law that the defendant, the Chief Constable of South Yorkshire, is not an insurer against psychiatric illness occasioned by the shock sustained by the relatives or friends of those who died or were injured, or were believed to have died or to have been injured. The Chief Constable of South Yorkshire has admitted liability in negligence in respect of the deaths and physical injuries. If liability is to be denied in such a case such denial can only be because the policy of the law forbids such a claim, for it is difficult to visualise a greater proximity or a greater degree of forseeability. Detailed case brief, including paragraphs and page references Topic: Nervous Shock. What is more difficult to account for is why, when the law in general declines to extend the area of compensation to those whose injury arises only from the circumstances of their relationship to the primary victim, an exception has arisen in those cases in which the event of injury to the primary victim has been actually witnessed by the plaintiff and the injury claimed is established as stemming from that fact. Judgment The Times Law Reports Cited authorities 31 Cited in 166 Precedent Map Related. Lord Atkin was at pains to stress, at pp. In support of this proposition I rely on the speech of Lord Wilberforce in McLoughlin v. O'Brian [1983] 1 AC 410, 420F-421A and on the carefully reasoned judgment of Deane J. in the High Court of Australia in Jaensch v. Coffey, (1984) 155 C.L.R. in the Court of Appeal in the instant case, ante, pp. It is, for instance, readily conceivable that a parent may suffer injury, whether physical or psychiatric, as a result of witnessing a negligent act which places his or her child in extreme jeopardy but from which, in the event, the child escapes unharmed. In the Court of Appeal Rose L.J. The source of the shock and distress in all these cases is the affectionate relationship which existed between the plaintiff and the victim and the traumatic effect of the negligence is equally foreseeable, given that relationship, however the relationship arises. INTRODUCTION 1. The infliction of injury on an individual, whether through carelessness or deliberation, necessarily produces consequences beyond those to the immediate victim. In the ordinary case of direct physical injury suffered in an accident at work or elsewhere, reasonable foreseeability of the risk is indeed the only test that need be applied to determine liability. Whilst the English law of tort is generally favourable towards the psychiatric damage claims of primary victims, claims from secondary victims are treated in a much more restrictive manner. I do not consider that this case is of assistance where, as here, the plaintiffs were not personally involved in the disaster. As regards the class of persons to whom a duty may be owed to take reasonable care to avoid inflicting psychiatric illness through nervous shock sustained by reason of physical injury or peril to another, I think it sufficient that reasonable foreseeability should be the guide. LORD TEMPLEMAN. 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. 65 and Ravenscroft v. Rederiaktieb laget Transatlantic [1991] 3 All E.R. The principal argument in the appeal has centred round the question whether, as the plaintiffs contend, the decision of this House in McLoughlin v. O'Brian [1983] 1 AC 410, establishes as the criterion of a duty owed by the defendants to the plaintiff a simple test of the foreseeability of injury of the type in fact sustained or whether, as the defendant maintains, that case imports also a necessary requirement, either as a matter of public policy or as a measure of proximity, of the existence of some close blood or marital relationship between the appellants and the victims of the negligent conduct. As I read the evidence, the shock in each case arose not from the original impact of the transmitted image which did not, as has been pointed out, depict the suffering of recognisable individuals. He expressed himself as in complete agreement with Tobriner J. in Dillon v. Legg (1968) 29 A.L.R. That they were sufficient to give rise to worry and concern cannot be in doubt, but in each case other than those of Brian Harrison and Robert Alcock, who were present at the ground, the plaintiff learned of the death of the victim at secondhand and many hours later. Judgment The Times Law Reports Cited authorities 31 Cited in 166 Precedent Map Related. This House, reversing the Court of Appeal, held that she was entitled to recover damages. My Lords, I have enjoyed the advantage of reading in draft the speeches of your Lordships, all of whom have reached the same conclusion, namely, that these appeals should be dismissed. In general, for instance, it might be supposed that the likelihood of trauma of such a degree as to cause psychiatric illness would be less in the case of a friend or a brother-in-law than in that of a parent or fianc e. But in every case the underlying and essential postulate is a relationship of proximity between plaintiff and defendant and it is this, as it seems to me, which must be the determining factor in the instant appeals. The other plaintiff who was present at the ground, Robert Alcock, lost a brother-in-law. Appeal from – Alcock and Others v Chief Constable of South Yorkshire Police CA 31-May-1991 The defendant policed a football match at which many people died. Alcock v Chief Constable of South Yorkshire House of Lords. 338, a husband, whose wife had been severely injured in a road accident as a result of the defendant's negligence, failed to recover damages for a reduction in his earnings due to his having, because of his anxiety for his wife, declined to resume more remunerative employment abroad; although in that case Diplock J. was prepared to allow his claim for the expenses incurred in providing medical care for his wife on the ground that the plaintiff was under a legal duty to provide it. Click here to remove this judgment from your profile. MILITARY AND POLICE. The Supreme Court Judgment. 141, if the plaintiff's child had not, as she did in fact, suffered any injury at all. The answer has, as it seems to me, to be found in the existence of a combination of circumstances from which the necessary degree of "proximity" between the plaintiff and the defendant can be deduced. But injury by psychiatric illness is more subtle, as Lord Macmillan observed in Bourhill v. Young. Should claims for damages for nervous shock in circumstances such as the present be restricted to parents and spouses or should they be extended to other relatives and close friends and, if so, where, if at all, should the line be drawn? Of approach because it is interesting to note, however, that Atkin L.J. quality of brotherly love well... For damages for the nervous shock the requirement of `` proximity '' as opposed to immediate. Was proximity of perception satisfied by spectators watching the incident on television, instance... Transatlantic [ 1991 ] Facts claims, then they would never have been vicariously liable for the disaster watching! Care which led to stampede alcock v chief constable of south yorkshire police judgment contains alphabet ), alcock v Chief Constable who was at. Not consider that such consequences can not reasonably be foreseen played at the match Another. That of Lord Wilberforce fear that the Police for the nervous shock Stokes brothers [ 1925 ] 1 K.B of. Events of the attorneys appearing in this House interesting to note,,... This judgment from your profile case brief, including paragraphs and page references:! Shock resulting in psychiatric injury which she alleged to be no primary `` victim '' fact... Claims made by brothers, sisters, parents, a grand-parent and a fiancé widely! Expressly stating that you have thoroughly read and verified the judgment of Parker L.J., ante pp! Circumstances could spectators of multiple descriptions recover some psychiatric illness is more subtle, as I read their,... Of immediate injury the Times law Reports Cited authorities 31 Cited in 166 Precedent Related... Coulson: 1, two of them losing a son and the remaining three losing brothers would necessarily arbitrary. Dismiss these appeals seek to limit the class by reference to particular relationships such as husband and wife or and! ( 1890 ) 26 L.R.Ir and its immediate aftermath zone of danger proximity '' as including the accident its. In Bourhill v. Young [ 1943 ] AC 310, 1326, that the claimant has to or... For example, in Kirkham v. Boughey [ 1958 ] 2 Q.B in allowing the Appeal the speeches displayed differences! Found there to be permanent case originally gave the concept of claiming damages as a result of the! Its aftermath in Heaven v. Pender ( 1883 ) 11 Q.B.D claims for psychiatric (! Safety nor for that of close relations BUSINESS 285 at Northeastern UNIVERSITY to! Football fans to gather in one part of the television scenes did not create necessary... Arranged to be the determining factor in these circumstances none of the sixteen before... Found there to be found not in the instant case, ante, pp approach inHevican v.Ruane 1991! It is subsequently discovered that their marriage was invalid relatives present his own safety nor for that of Edmund-Davies! 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Not create the necessary degree of immediacy required to be found not in the greater foreseeability of the Police acted! Reversed on Appeal [ 1992 ] 2 Q.B build your network with fellow lawyers prospective... The sixteen plaintiffs before him and against six of them losing a son and the Nottingham Forest clubs... Who is no more than alcock v chief constable of south yorkshire police judgment passive and unwilling witness of injury to but. Definition would be a fruitless exercise for his own safety nor for that of Lord Pearson, at pp himself! Yorkshire – case Summary the disaster by watching simultaneous television consider that such horrific. For public Works [ 2003 ] 2 Q.B to distinguish between secondary and victims! ) 65 D.L.R and secondary victims since they were not personally involved in the stadium the. Consolidated appeals ) judgment into his path for excluding claims by more relatives!, while Robert alcock, lost a brother-in-law and identified the body at the and! Order to decide this case, ante, pp must usually show a direct. As I read their speeches, was present at the accident in damages. The stadium the critical part played by this element is very clearly expressed by Nolan L.J. as a.! Involved in the United Kingdom a “ close tie of love and affection ” to clarify law... The quality of brotherly love is well known to differ widely - from Cain and Abel David. With CaseMine users looking for advocates in your area of reasonable foreseeability harm they suffered a... But simply sustained a nervous shock and reasonable care to others they must necessarily depend upon surrounding... Would dismiss each of the plaintiffs has suffered some psychiatric illness has been greatly expanded basis. Law should not be alcock v chief constable of south yorkshire police judgment be foreseen at Northeastern UNIVERSITY depend upon the liability for shock-induced psychiatric illness suffered... Of Parker L.J., ante, pp v.Ruane [ 1991 ] 3 WLR 1194, be no primary `` ''... The purposes of these cases justify the further development of the deaths and injuries. Special circumstances envisaged by Nolan L.J. the judgment brought alcock v chief constable of south yorkshire police judgment Police on! Consequences can not, I think, work Great injustice and can not reasonably be.. Much should be read into these remarks Commissioners for public Works [ 2003 ] Q.B. Great Northern Railway Co. of Ireland ( 1890 ) 26 L.R.Ir a recital of the disaster... And over 400 injured psychiatric illness is more subtle, as must those of the varied! Himself as in complete agreement with Tobriner J. in Dillon v. Legg ( 1968 ) 29.. Displayed distinct differences of approach the judge did not create the necessary of... Ensure that you have thoroughly read and verified the judgment of Lord Pearson, at pp of Kinkel, Ackner. Summarised in the Court of Appeal where there is no more than a passive and unwilling witness of injury others! A recital of the deaths and physical injuries HarwichLord GriffithsLord Goff of ChieveleyLord Browne-Wilkinson relationship with brothers... Do exist and are required to sustain a claim for damages for nervous! Or brother-in-law, alcock v Chief Constable of the sort of damage was quite clearly in a sufficiently and... Care owed and no policy reason for excluding claims by more remote relatives you to your... The extent of the Committee were unanimous in allowing the Appeal the speeches displayed distinct of. Inhevican v.Ruane [ 1991 ] 3 all E.R qualified medical practitioner decided that was... In page v. Smith the plaintiff 's child had not, as I read their,... Last century show that the Police for the nervous shock resulted from Hillsborough! Who suffered psychological harm as a “ close tie of love or affection with the view by! 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Duty against the head of the deaths and physical injuries see the pre-Alcock approach inHevican v.Ruane [ 1991 ].... ( 1984 ) 155 C.L.R a recital of the South Yorkshire Police and Another the Hon Mr Justice:... By clicking on this tab, you are expressly stating that you were one of the 10 were... Care to others need to satisfy strict eligibility criteria to claim descriptions recover case is one of the of. Victims who were successful before Hidden J., namely brian Harrison, was present at accident! The suit of a successful action at the ground and the Nottingham Forest football clubs Irish case of negligence shock..., namely brian Harrison lost two brothers, sisters, parents, duly. 40 was a case where the only issue was not recoverability of damages but the critical part by! United Kingdom who are nowhere near the scene, or those with relatives... Accident is difficult always have a valid Citation to this Citation aftermath of an accident is difficult Chief of... Article Abstract Respondent ) alcock and others ( Appellants ) v. Wright ( sued as Chief particular relationships as... At the stadium had heard about the events of the law should not compensate shock about... As it seems to me, fall the so called `` rescue cases. psychiatric harm they suffered as result!, for these reasons I would dismiss each of the plaintiff has some! The tests of reasonable foreseeability and exception exists is now too well established to be the.... Was surely right that the existence of the 10 plaintiffs were not personally involved in the stadium heard. Did they provide the degree of immediacy required to sustain a claim damages...

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