1- MUST be a recognised psychiatric illness:
Nervous shock, post traumatic stress disorder, severe depression, pathalogical grief disorder-Vernon.
Grief, distress,, fright not included- Reilly- discomfort in lift
2- Primary Victim- at the scene Rescuers must be primary victims, Hale-fireman
Dulieu v white and sons- 'reasonable fear of immediate personal injury to oneself'
Injured: Simmons- employer liable for damages at work place
Not injured but threatened: Page v Smith- pvs only need to show some kind of physical injury was foreseeable. Secondary victims need to show personal injury WAS foreseeable, 'eggshell personality' applies.
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