In Alcock v Chief Constable of South Yorkshire Police (1991), Lord Oliver drew a distinction. He stated that primary victims are those directly involved, either immediately or mediately, as a participant. Additionally, Page v Smith (1995)- Lord Lloyd stated a primary victim is directly involved in the accident and well within the range of foreseeable physical injury.
However, secondary victims are those who are no more than passive and unwilling witnesses of injury caused to others.
Stress At WORK:
This may also lead to psychiatric damage due to pressure in the workplace.
In Walker v Northumberland County Council (1995), the claimant was successful after suffering a second mental breakdown caused by stress at work. After the first breakdown, the employers had stated that his workload would be reduced, but no steps were taken to do this.---> Reasonably foreseeable that the claimant would suffer breakdown if the workload wasn't reduced. He could recover as a Primary VICTIM.
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