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Secondary victims—the developing case

law
May 25, 2016 By LexisNexisUK Blogs (http://blogs.lexisnexis.co.uk/dr/author/paul-foxton-2/) — 1 Comment
(http://blogs.lexisnexis.co.uk/dr/secondary-victims-the-developing-case-law/#comments)

(http://blogs.lexisnexis.co.uk/dr/wp-
content/uploads/sites/2/2016/05/42755114_xl.jpg)This an
exclusive blog post based on a Lexis®PSL Practice Note on
the developing case law around secondary victims. It has
been produced in partnership with Andrew Wilson
(http://lexisweb.co.uk/users/andrew-wilson?
webSyncID=bc1875c0-a6d5-5ca6-1eca-
8aceb5281334&sessionGUID=1e17561b-a24d-e818-cedd-
21c1ba887916).

Post-Alcock

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1/13/2018 Secondary victims—the developing case law

The Court of Appeal has, in the years since the House of Lords’ Alcock judgment, been required to explore
the limits of the event and its immediate aftermath.

In Taylorson v Shieldness Produce Ltd, a14-year-old boy suffered very severe head injuries when dragged
under an HGV. His parents were not present at the accident but learned of it, very soon after it occurred,
when telephoned and then visited by the police. The parents drove to the hospital to which their son had
been taken but when they arrived were told that he was being transferred on to another hospital. They
followed the ambulance to the second hospital and on arrival the boy’s mother saw her son’s feet as she
passed the ambulance. Inside the hospital, the son passed his parents as he was wheeled to the intensive
HOME
care unit. (/DR/)
The mother ABOUT (HTTP:/
saw blood /BLOGS.LEXISNEXIS.CO.UK/DR/ABOUT/)
on her son’s face while the father saw a hand hanging out. Following
treatment and around eight or nine hours after the accident, the father saw his son’s face bloody and
bruised and a tube (HTTP:/
CONTRIBUTORS attached to his head. The day after the accident, both mother and father saw their son
/BLOGS.LEXISNEXIS.CO.UK/DR/CONTRIBUTORS/)
unconscious. Three days after the accident, the father gave consent for the life support machine to be
switched off.

The Court of Appeal held that what the parents had witnessed was not the immediate aftermath of the
accident. McCowan LJ felt that a nding of proximity would constitute ‘a very considerable extension of the
law as laid down in Alcock’.

In the case of Walters v North Glamorgan NHS Trust the hospital had failed to diagnose a baby’s acute
hepatitis. The baby suffered a major epileptic t and then deteriorated over the next 36 hours till it died. The
Court of Appeal held that there was a ‘shock’ in a single traumatic event which had caused the mother to
suffer psychiatric injury. Ward LJ stated (at para 34) that the word ‘event’ had a wide meaning, and that
de ning whether something forms part of an event:

‘…is a matter of judgment from case to case depending on the facts and circumstances of each case.‘

In Walters the event in question was:

‘…a seamless tale…played out over a period of 36 hours.’

Likewise, notwithstanding the time period in question, the court held that the claimant’s appreciation of
events was sudden and shocking, rather than being a more gradual assault on her mind over a period of
time (in which case her claim would have failed on the authority of Alcock).

In Galli-Atkinson v Seghal—the claimant’s 16-year-old daughter was killed when struck by a car which had
mounted the kerb. The girl was pronounced dead around 30 minutes after the accident. The mother (the
claimant) arrived at the scene, searching for her daughter, about an hour after the accident. At the police
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1/13/2018 Secondary victims—the developing case law

cordon, she was advised that her daughter had died. There was no evidence that, while at the scene, she
saw any evidence of what had happened to her daughter, whose body had been removed. The claimant was
taken to the mortuary, where she held the body. Her daughter was horri cally injured, and although some of
those injuries were covered, her face and head, which were dis gured, were seen.

The claim initially failed on the basis that the claimant did not satisfy all of the Alcock control mechanisms,
but then succeeded in the Court of Appeal with the court stating that in this case ‘the immediate
aftermath…extended from the moment of the accident until the moment that the [claimant] left the
mortuary’. If the psychiatric evidence showed that the whole sequence of events played a part in producing
the injury, the claim should succeed.

In Taylor v A Novo the claimant was the adult daughter of the victim of an accident at work. The claimant
did not witness that accident but did witness her mother’s death three weeks later from a blood clot
resulting from injuries suffered in the accident. The Court of Appeal held that the daughter could not be
classed as a secondary victim as she was not proximate to the relevant event: Taylor v A Novo [2013] All ER
(D) 167 (Mar).

In Wild v Southend Hospital NHS Trust, the claimant was in hospital with his wife on the due date for delivery
when it was discovered that the baby had died in the womb. The hospital admitted both negligence in the
failure to monitor the growth rate of the foetus during pregnancy and causation, in that but for this failure,
labour would have been induced at an early enough point for the baby to be born alive. However, the claim
failed on the basis that the retrospective discovery that the baby had died in the womb could not satisfy the
test of witnessing horri c events leading to or surrounding serious injury or death.

Brock v Northampton General Hospital NHS Trust was concerned with a claim by parents of a patient who
died from a brain haemorrhage after an intracranial pressure monitoring bolt was inserted too far into her
brain. The judge found that nothing traumatic had occurred at the time of the negligent insertion, while the
parents did not allege that their psychiatric injury was caused by anything witnessed at the bedside. The
judge held that there was no traumatic experience such as to found liability.

Berisha v Stone Superstore Ltd, —the claimant was informed by police that her partner had suffered serious
injury in an accident at work. When she arrived in hospital ve hours after the accident, her partner was on a
life support machine, as he had suffered a severe brain injury. She was then with him by his bedside for the
next 36 hours until she agreed to the life support machine being switched off. The claim was struck out on
the defendant’s application as there was no prospect of establishing that the claimant witnessed the
immediate aftermath of the accident. She was unable to identify a single drawn out event or seamless tale.

Mechanism of injury: ‘a sudden and horrifying event’?

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1/13/2018 Secondary victims—the developing case law

There is no prescriptive list of the types of event that might qualify. A series of shocking components that
form part of a group, each of which contribute to a claimant’s psychiatric injury, can be considered an event.

Shorter v Surrey & Sussex NHS Healthcare Trust—the claimant was the sister of a patient of the trust who
had died as a result of the trust’s admitted negligence, in failing to accurately report a CT scan of the brain
and in thereby delaying diagnosis of a subarachnoid haemorrhage caused by a cerebral aneurysm. The
timeline had been as follows:

5 May 2009—claimant’s sister collapsed at home and was rushed to East Surrey Hospital, where she
underwent a CT scan, which was reported to be normal. She had no further investigations and no
explanation for her collapse was found. She was discharged home. (The consultant neurologist at
East Surrey had had reservations about the scan and had arranged for it to be reviewed by a
neuroradiologist)
12 May 2009—the neuroradiologist nally undertook the review and recognised that there was
evidence of a bleed. The claimant’s sister was called back immediately to East Surrey and the
intention was to transfer her urgently to St George’s Hospital in London. In the event, the transfer did
not take place until about midnight.
13 May 2009—after suffering a series of seizures in the early hours the claimant’s sister was placed
on life support and intubated but died at 12.45.

NOTE: there was evidence adduced as to the closeness of the relationship between the claimant and her
sister. The defendant accepted ultimately that the closeness of their relationship brought the claimant
within the class of persons eligible to bring a claim.

The claimant sought to establish that there had been a ‘seamless single horrendous event’ over two days,
starting on the morning on which the bleed was correctly diagnosed, her distress being compounded by the
claimant’s own professional experience as a senior nurse in neuro-intensive care.

The judge found that the claimant became aware of the trust’s negligence and its repercussions when she
received a telephone call from her sister’s husband on the morning of 12 May. At that point the claimant did
not have ‘physical proximity’ to events at the hospital. Furthermore, the judge found that when the claimant
attended the accident and emergency department that morning her sister’s condition was not such that it
could be described as a ‘horrifying event’ or could cause a ‘violent agitation to the mind’.

The judge found that there had been a gradual accumulation of different events causing assaults on her
mind resulting in her psychiatric injury, as opposed to the ‘seamless tale’ as in Walters.

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1/13/2018 Secondary victims—the developing case law

In Liverpool Woman’s Hospital NHS Foundation Trust v Ronayne the Court of Appeal considered whether a
husband who suffered mental illness as a result of seeing his wife in a shocking condition following a
hysterectomy operation could claim damages as a secondary victim. The husband’s claim failed because,
despite the claimant being able to prove he was genuinely shocked and distressed after seeing his wife, he
was unable to:

identify a speci c and extreme event

prove the event had a su ciently sudden and shocking nature, and
evidence that the sudden and shocking event had caused his psychiatric illness

Further Guidance
Lexis®PSL Personal Injury subscribers enjoy a wealth of expert analysis. For further guidance on the
establishing a secondary victim, see Practice Note: Secondary victims
(https://www.lexisnexis.com/uk/lexispsl/disputeresolution/document/393875/5HMB-BDG1-F18H-
M3NW-00000-00/Secondary%20victims).

Click here for a free trial to access if you are not a PSL subscriber
(http://blogs.lexisnexis.co.uk/dr/free-one-week-trial-of-lexispsl-arbitration/).

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Filed Under: Personal Injury (http://blogs.lexisnexis.co.uk/dr/category/pi/)

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Trackbacks
Psychiatric injury and secondary victims- no extension of the Alcock rule
(http://blogs.lexisnexis.co.uk/dr/psychiatric-injury-and-secondary-victims-no-extension-of-the-alcock-
rule/) says:
May 25, 2016 at 3:51 pm (http://blogs.lexisnexis.co.uk/dr/secondary-victims-the-developing-case-
law/#comment-433800)
[…] posted an article in May 2016 on the developing case law for secondary victims.  Lexis®PSL Personal
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