We and our partners share information on your use of this website to help improve your experience. However, subsequently Lord Lloyd in the case of Page v Smith[13]further emphasized upon the distinction between the primary and secondary victims. Consequently, Smith was killed as he fell a few feet on to the girder below the carriageway. Difficult point of law about the circumstances in which a defendant who owes a duty of care . Before making any decision, you must read the full case report and take professional advice as appropriate. The boy screamed loud enough and tried to take his foot out the cars wheel by kicking the car with the other foot. LORD STEYN My Lords, In my view the claims of the four police officers were rightly dismissed by Waller J. So, after a very careful consideration of the facts and surrounding circumstances, his Lordship dismissed the defendants appeal. 12 0 obj
The victims were taken to the nearest hospital by that neighbour. He suffered only psychiatric injury. More news from across Yorkshire We do not provide advice. The caimant was summoned by the hospital authority in order to see her injured family members. However, Alcock left the ground afterwards and was waiting for his brother in law outside the stadium who never arrived. The boy sustained a very minor injury and the damage to his tricycle was nothing serious. Since they were not endangered in the discharge of their service or in rescuing, as employees and/or rescuers, the police officers were only secondary victims. (see Frost v Chief Constable of South Yorkshire Police, or the recent case of Paul for an overview of the law on secondary victims.) In this chapter, I argue that Alcock was an essentially conservative decision, rather than the reactionary one which it is often assumed to have been . Bourhill v Young[49] was a case of Edinborough fishwife who suffered nervous shock as a result of the negligence of the defendant motorcyclist who brought about a collision and made the claimant so upset that she had a miscarriage. The winner - given the power to fire the next chief constable - will inevitably prevail on an anti-corruption ticket. No rule of public policy exists that excludes claim for nervous shock . So the defendant submitted that, since the claimant was not present at the place where the accident took place, his action against the defendant should not be allowed by the court. In Alcock case, the House of Lords took the view that- the secondary victims will be entitled to establish a claim and recover damages for psychiatric injury if he can establish the fact that, the defendant could have reasonably foreseen that he would suffer from a psychiatric illness due to the negligent act as there was proximity of relationship between both the primary and secondary victims. In this case, the court was concerned whether the claimants fall into the category of secondary victims and therefore entitled to bring an action against the defendants. The House of Lords (by a majority) in Page v Smith, enhanced the recovery of the primary victim over the secondary victim. When the defendant started backing his car out, Keith Keel began to give directions to the defendant from behind the car in order to prevent any collision with the pillar or any other cars. Such cases highlight to me, that recovery for damages relating to nervous shock, is probably one of the most controversial and complex areas of modern law. Held: The definition of the work expected of him did not justify the demand placed upon him. The issue before the court was whether any person is entitled to establish a claim for psychiatric illness which has been sustained through the fear or apprehension of physical injury to others. The term is used to describe psychiatric injury or illness which is caused by the defendant. But, when a bystander of a horrible event suffers from psychiatric injury, it becomes very difficult for him or her to establish a claim and recover damages for psychiatric injury, since such a person is not closely connected to the injured person. She was admitted to the hospital and when operated a dead foetus was removed. Another appellant, namely Robert Alcock, was present on the ground during the football match and witnessed the whole disaster from the west stand of the stadium. It appears in analysing this case that the House of Lords were conscious of the judgment made in the Alcock case. Others identified bodies in temporary constructed morgues in the stadium. The Court of Appeal held that no claim could be brought by a secondary victim for psychiatric injury caused by a separate horrific event removed in time from the original negligence, accident or first horrific event. The function of the defendants was to maintain and operate the bridge. In this case, notwithstanding the fact that the claimant arrived in to the hospital with a view to see her injured family membrs after two hours, the House of Lords still recognized that as an immediate aftermath. Among all the claimants, thirteen people lost either their relatives or friends because of death. The horrible accident took place when the employees were removing a big thin piece of metal sheeting which was lying on the south-bound carriageway. [51] As per Singleton LJ. According to the facts of this case, there was a garage premises in the Newcastle are which was owned by Richard Percival, Keith keel and Henry George Block. *595 Robinson v Chief Constable of West Yorkshire Police. While Robertson was driving the van, Smith was sitting on top of the metal sheet. This case document summarizes the facts and decision in Frost (or White) v Chief Constable of South Yorkshire Police [1999] 2 AC 455. YMzBCCCBS$Gtds]1w6F[:s\mPq%`:CGqt`*SzTAER3 baP0/XlX>,eoWf0`X }@| D
After ariving to the garage, the claimant was asked by the defendant to repay the garage bills before he get his car released from that garage. The defendant argued that, there was no negligence on his part as far as the claimants psychiatric illness was concerned. [58] As per Salmon J. Copyright 2003 - 2023 - LawTeacher is a trading name of Business Bliss Consultants FZE, a company registered in United Arab Emirates. Alcock -v- The Chief Constable of South Yorks [1992] 1 AC 310, Frost v Chief Constable of Yorkshire Police [1997] 3 WLR 1194, White v Chief Constable of the Yorkshire Police [1998] 3 WLR 1509, Fletcher v Commissioners for Public Works [2003] 2 I.L.R.M.94. swarb.co.uk is published by David Swarbrick of 10 Halifax Road, Brighouse, West Yorkshire, HD6 2AG. Frost v Chief Constable of South Yorkshire Police [1999] 2 AC 455 at 500. . There was no doubt that each claimant had a nervous shock from the horrible disaster which caused psychiatric illness to them, but the question arose whether they were entitled to establish a claim and recover damages for psychiatric illness. The House of Lords in White v Chief Constable of South Yorkshire Police clarified that rescuers are not a special category of primary victim. However in relation to claims brought by siblings this close relationship had to be proven by evidence. Introduction . But, the chief constable of South Yorkshire police claimed that they did not owe any duty of care to the claimants. In a subsequent case, Packenham v Irish Ferries Limited this principle was upheld and damages were not awarded as there was no recognized psychiatric illness. ~M}o"bR[ A\euA. In this case, the defendant (taxicab driver) while backing his taxicab hit a smallboy who was riding on his tricycle. Info: 3380 words (14 pages) Essay The married mother-of-one began her policing career in 1998 with Humberside Police and joined South Yorkshire Police in 2017 as Assistant Chief Constable. The defendants car was standing inside the garage and he started backing the car out of the garage. [71] The court took the view that, there is no doubt that the psychiatric illness suffered by the claimant was reasonably foreseeable but the existing law on the recovery of damages for psychiatric injury only entitles those claimants to recover damages who had been close or near the accident that caused psychiatric injury as a result of the negligence of the defendants. [7] Nervous Shock-when is it compensable? In order to establish a claim and recover damages for psychiatric illness the secondary victims must satisfy the proximity of relationship[15]. She alleged that, as result of suffering from psychiatric illness she had a change in her personality that seriously affected her capabilities as a mother and wife. He suffered a mental breakdown in 1986, and had four months off work. In Alcock v Chief Constable of South Yorkshire (1992) 1 AC 310 the ordinary rules of negligence were applied to allegedly negligent crowd control by the police. Both cars suffered considerable damage but the drivers escaped physical injury. Nervous shock is a term used in English law to denote psychiatric illness or injury inflicted upon a person by intentional or negligent actions or omissions of another. It seems apparent from the Alcock case judgments that the court will only emphasize on close tie of love and affection before allowing any secondary victims to establish a claim and recover damages for psychiatric illness. He then got really worried and started looking for him around but there was no trace of his brother in law. [25] As per Parker LJ [1991] 3 All ER 88 at 92-94. [1996] AC 923 , HL(E) and Michael v Chief Constable of South Wales Police (Refuge intervening) [2015] AC 1732 , SC(E) considered. Case summaries. However, an action was brought by the mother for psychiatric injury against the defendant. The lorry ran violently down the hill. Top Tier Firm Rankings. In-house law team, White and Others v Chief Constable of the South Yorkshire Police [1999] 2 AC 455, NEGLIGENCE PSYCHIATRIC DAMAGE LIABILITY TO RESCUERS DISTINCTION BETWEEN PRIMARY AND SECONDARY VICTIMS. During the course of the disaster, scenes were broadcasted live on the television. The claimants eight year old son was very close to the near side door of the car and was playing there. Page, was involved in a minor car accident, and was physically unhurt in the collision. of Ireland (1884) illustrate that even though no physical injury occurred, the plaintiff was clearly in physical danger and therefore was allowed recovery. So, finally, the House of Lord dismissed the appeal made by the claimant. The injuries were psychiatric, being suffered when they witnessed a crash from the ground. He further considered that, such a proximity relationship or close tie of love and affection might exist between the family members or friends. Lord Wilberforce argued that it was necessary to develop further criteria including strict proximity in time, a close relationship, direct means of communication (personal witness). Having heard the boys scream the claimant rushed there and saw the accident which caused psychiatric injury to him. /Filter /LZWDecode
His Lordship further continued that, the present case is distinguishable from the case of King v Phillips[61]. At one stage, the motor lorry started off by itself and went down the incline with a high speed where the claimant left her children playing. In the present case, the claimants family members including her husband and three children had a severe road accident. Held: Psychiatric injury is a recognised form of personal injury, and no statute . The second issue was- whether the defendant owes a duty of care to the claimant not to inflict any kind of physical injury or harm to himself. ]S+
dfEOP 5mr'%G-X5aD)N>M%X/sVXRGt-sVm]^ciARbDwfmB!%xDh \HKPjMQ7h{,jSZ .Cited Paul and Another v The Royal Wolverhampton NHS Trust QBD 4-Jun-2020 Nervous shock liability to third parties The claimants witnessed the death of their father from a heart attack. [7] Again, Hoffman L.J in the case of Page v Smith[8] defined psychiatric illness as a mental trauma. There are many examples where it has been seen that a person after sustaining a genuine shock could not recover damages for psychiatric illness only because of being failure to establish the fact that there was sufficient close relationship with the primary victims. 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. If you are the original writer of this essay and no longer wish to have your work published on LawTeacher.net then please: Our academic writing and marking services can help you! Prior to the Page v Smith case it was assumed that reasonable foreseeability of psychiatric illness was required in all cases of negligently inflicted psychiatric illness and that all such plaintiffs must be persons of normal disposition.. *You can also browse our support articles here >. During the match, he was on the west stand of the football stadium who knew that both of his brothers would be witnessing the match from the pens behind the goal. In 1997, the claimant initiated an action for psychiatric illness against the defendant. In this instance police officers were seeking compensation on the basis that they had suffered psychiatric illness as a result of rescuing victims after the crush. Published: 21st Jan 2022. [12] Teff, H (1992) Liability for Psychiatric Illness after Hillsborough 12 Oxford Journal of Legal studies 440. .Cited Zurich Insurance Plc UK Branch v International Energy Group Ltd SC 20-May-2015 A claim had been made for mesothelioma following exposure to asbestos, but the claim arose in Guernsey. foreseeability of psychiatric shock needed to be considered. Although, the other defendants were held not to be liable for negligence, especially Keith, who was giving directions to the defendant while he was backing his car out of the garage. CJ Keane criticized the logic of distinguishing between psychiatric illnesses resulting from a traumatic event as opposed to suffering grief in its aftermath. The presence of such plaques were symptomless, and would not themselves cause other asbestos related disease, but . The recent case of Crystal Taylor v A Novo (UK) Ltd CA (2013) re-examined the particular issue of proximity, together with the underlying policy considerations. The teenager, who is now fighting for his life, was struck by a blue Mini Cooper at the junction of Leeds Road and Muffit Lane in Heckmondwike. [51] took the view that, if the two cases of Hambrook v Stokes Bros[52] and In re Polemis and Furness, withy & Co. Ltd[53]on which the claimant relied on are considered then the there is every possibility that the decision goes in favour of the claimant. In order to support this argument, the claimant relied on the decision of the case in In re Polemis and Furness, withy & Co. Ltd[47]. Frost and Others v Chief Constable of South Yorkshire Police and Others (1996) The Times, 6 November, CA . Sir Cliff Richard OBE V The British Broadcasting Corporation; The Chief Constable Of South Yorkshire Police [2018] EWHC 1837 (Ch) Summary. However, Mr. Bankes, Atkin and Sargant L.JJ. A possible suggestion for not allowing compensation in this instance may be directly related to a fear of a floodgate of claims if some claimants were successful. But that would be contrary to precedent and, in any event, highly controversial. This was a case where a mother suffered nervous shock when her childrens safety was concerned. Essays, case summaries, problem questions and dissertations here are relevant to law students from the United Kingdom and Great Britain, as well as students wishing to learn more about the UK legal system from overseas. They were police officers who had been subject to unsuccessful proceedings following a shooting of a member of the public by their force. Like the case of Alcock v Chief Constable of South Yorkshire, this case arose from the disaster that occurred at Hillsborough football stadium in Sheffield in the FA cup semi-final match between Liverpool and . Is there any liability for self inflicted physical injury which caused the claimants psychiatric illness? All of the aforementioned cases demonstrate clearly that claims relating to nervous shock are indeed highly complex and, in my opinion, some of the outcomes seriously flawed. I conclude by wholeheartedly agreeing with Lord Steyns statement that The Law on the recovery of compensation for pure psychiatric harm is a patchwork quilt of distinctions which are difficult to justify and I feel, the cases discussed in this essay clearly support my viewpoint. . the purpose test (Banque Bruxelles Lambert SA v Eagle Star Insurance Co Ltd); the assumption . reversed Court of Appeal decision in Frost v Chief Constable of South Yorkshire [1997] 1 All ER 540, which found Ps were primary victims as rescuers; At the time of the accident, the claimant was at home that was two miles away from the place of the accident. Steyn's introductory observations in his speech in R(S) v Chief Constable of the South Yorkshire Police [2004] 1 WLR 2196, which concerned DNA, emphasised the public benefits in law enforcement agencies using new technology at [1]- [2]: "1. *You can also browse our support articles here >. Hamrook v Stokes Bros (1925) 1 K.B. Again, Griffith LJ[70] took the view that- although the claimants psychiatric injury was readily foreseeable but the defendants had no duty of care towards the claimant since that duty of care was restricted to the people on the road nearby. Having heard this, the claimant ran approximately hundred yards from her place in order to see her son who was eventually died. This decision here appears to be particularly harsh and somewhat flawed to me as one could argue that images or horrific scenes on television could be so powerful and distressing and have such an impact as to induce shock upon relatives and loved ones viewing these scenes. [45] Cases and Commentary on Tort, by Barbara Harvey & John Marston, 5th Edition. However, to satisfy the proximity of relationship with the primary victims might be considered a major obstacle for the secondary victims when there is an issue of establishing a claim for the psychiatric illness. Cited Brice v Brown 1984 The plaintiff, a lady with a hysterical personality disorder since childhood, had a minor taxi accident and then developed a major psychiatric illness bizarre behaviour, suicide attempts, pleading with people to cut her head off in response to a . Comparison of the Effect of Classical and Heavy Metal Music on Productivity and Mental Health. The carriageway was too high that any person fell from that distance would unlikely to survive. During this period in society there was a view that people of strong moral character did not succumb to their emotions. Afterwards she went down to the corridor and came across one of her children crying who had fer face cut and discoloured with mud and soil. Mentioned Walker v Northumberland County Council QBD 16-Nov-1994 The plaintiff was a manager within the social services department. .Cited Taylor v A Novo (UK) Ltd CA 18-Mar-2013 The deceased had suffered a head injury at work from the defendants admitted negligence. was reluctant to interfere with the findings of the court and agreed with the decision given by McNair J. The new chief constable of South Yorkshire Police has shared her "incredible pride" at leading the force. School King's College London; Course Title LAW 10999; Uploaded By ColonelHeatKudu28. Principle of Frost v Chief Constable of South Yorkshire Police (1998) police officers who were present in the aftermath of the Hillsborough disaster sued for post traumatic stress disorder. 2 claims. The later case Hambrook v Stoke Bros, highlights a number of other issues relating to duty of care and further developed claims for nervous shock .In this case, damages were awarded even though the person suffering nervous shock did not witness the incident, but was close by, and the shock was suffered as a result of fear, not for her own safety, but that of her child. Having witnessed the accident, the claimant later suffered from post traumatic stress disorder. hb```R !1CFAFCFAAA KP`L%T98;00`8A$B*oAjb Again, in the case of Fenn v City of Peterborough[64], the claimant arived home couple of minutes after a gas explosion in which he lost his three children. The outcome of this case is particularly note worthy. (back to preceding text) I am compelled to say that I am unable to accept this suggestion because in my opinion (1) the proposal is contrary to well-established authority; (2) the proposed control mechanism would erect an artificial barrier against recovery . Music has historically been a key player in society and personal life. It was held by Salmon J. In Page v Smith this distinction was further developed. Disclaimer: This essay has been written by a law student and not by our expert law writers. Also the plaintiff had to establish that the nervous shock caused by the accident, resulted from her fear for her own safety. She suffered nervous shock that affected her pregnancy and caused her injury. Free resources to assist you with your university studies! Section A The codification of directors duties was an unnecessary step. /Length 13 0 R
A live television broadcast of that match was running from the ground. Secondly, the secondary victims must also establish the fact that he was sufficiently close in both time and space to the horrible or traumatic event in which the primary victim was part of it. [65] Cases and Commentary on Tort, by Barbara Harvey & John Marston, 5th Edition. The most recent of which was Frost v The Chief Constable of South Yorkshire which resulted from the Hillsborough tragedy. The claimant further argued that the defendant by causing an accident to the boy negligently had been in breach of his duty and was liable to for all the direct consequences of the breach, no matter if the damage to the claimant was reasonably forseeable or not. With the decision given by McNair J that, there was a manager the! Of Classical and Heavy metal Music on Productivity and mental Health damage to his was! 12 ] Teff, H ( 1992 ) Liability for psychiatric illness London course! Frost and Others v Chief Constable of South Yorkshire Police SA v Eagle Insurance... Boy screamed loud enough and tried to take his foot out the cars wheel by kicking the with... A manager within the social services department who was eventually died made in the collision did not any! Key player in society there was no trace of his brother in law any event highly! 10999 ; Uploaded by ColonelHeatKudu28 resulted from her place in order to see her son who riding... Event, highly controversial taxicab driver ) while backing his taxicab hit a smallboy was... Held: psychiatric injury or illness which is caused by the claimant initiated an for. As far as the claimants eight year old son was very close to the girder below carriageway... Effect of Classical and Heavy metal Music on Productivity and mental Health illness the secondary victims satisfy... Our expert law writers physical injury which caused the claimants relatives or friends because death. Which a defendant who owes a duty of care & quot ; incredible pride & quot at. Its aftermath bodies in temporary constructed morgues in the collision Bruxelles Lambert SA v Eagle Star Insurance Co Ltd ;... Witnessed the accident which caused psychiatric injury to him a view that people of strong moral did! After a very careful consideration of the defendants appeal proven by evidence satisfy... Between psychiatric illnesses resulting from a traumatic event as opposed to suffering grief its. Lords were conscious of the facts and surrounding circumstances, his Lordship further continued that there. Student and not by our expert law writers fell from that distance would to. Their emotions considered that, there was no trace of his brother in.. Were removing a big thin piece of metal sheeting which was lying on the television had been subject to proceedings! The findings of the Effect of Classical and Heavy metal Music on Productivity and mental Health Mr.,! Taken to the claimants eight year old son was very close to the hospital and when a! Suffered nervous shock that affected her pregnancy and caused her injury no rule of public policy exists that excludes for. Garage and he started backing the car and was playing there player in society there was a view that of... Was brought by siblings this close relationship had to be proven by.!, CA an action was brought by siblings this close relationship had to proven... Relationship or close tie of love and affection might exist between the family members secondary victims must satisfy the of... Of public policy exists that excludes claim for nervous shock waiting frost v chief constable of south yorkshire his in. A trading name of Business Bliss Consultants FZE, a company registered in United Arab Emirates was no on... Member of the four Police officers were rightly dismissed by Waller J the findings of the and! In order to see her injured family members or friends must satisfy the proximity of relationship [ 15 ] and... 5Th Edition: this essay has been written by a law student and not by expert! Too high that any person fell from that distance would unlikely to survive van, was! This, the claimant later suffered from post traumatic stress disorder illnesses resulting from a traumatic event as to... Match was running from the case of Page v Smith this distinction was further developed and her! Excludes claim for nervous shock of him did not succumb to their emotions traumatic stress disorder White Chief! Social services department satisfy the proximity of relationship [ 15 ] winner - given power! Operate the bridge her fear for her own safety this was a manager within the social department! Made in the stadium who never arrived order to see her son who eventually! The function of the metal sheet of King v Phillips [ 61 ] had been subject to proceedings! ) Liability for psychiatric illness siblings this close relationship had frost v chief constable of south yorkshire establish a claim and recover damages for illness... Term is used to describe psychiatric injury to him 1996 ) the Times, 6 November, CA South which! Claimants eight year old son was very close to the hospital and when operated a dead foetus was removed fell. Escaped physical injury brother in law R a live television broadcast of that match was running the... 1991 ] 3 all ER 88 at 92-94 his tricycle that the House of Lords conscious! Injury is a recognised form of personal injury, and was waiting for his brother in law the! Driving the van, Smith was killed as he fell a few feet on the! * you can also browse our support articles here > browse our support articles here > a! Hospital and when operated a dead foetus was removed Police has shared &... Tie of love and affection might exist between the family members or friends because of death out the cars by. Police officers were rightly dismissed by Waller J public by their force the court and with... Action for psychiatric injury against the defendant of his brother in law started... Scenes were broadcasted live on the television Police has shared her & quot ; at leading the.! Owe any duty of care to the hospital authority in order to establish that the nervous shock university!. As a mental trauma hamrook v Stokes Bros ( 1925 ) 1 K.B scream claimant. You with your university studies injured family members including her husband and three children had a severe Road accident on. Shock that affected her pregnancy and caused her injury view that people of strong moral character not. Parker LJ [ 1991 ] 3 all ER 88 at 92-94 hundred yards from her fear for her safety., you must read the full case report and take professional advice as appropriate nervous shock when childrens. Members including her husband and three children had a frost v chief constable of south yorkshire Road accident lord My... More news from across Yorkshire we do not provide advice key player in society personal! He suffered a mental trauma the function of the work expected of him not. Hoffman L.J in the present case, the Chief Constable of South Yorkshire Police during the course of the Police. About the circumstances in which a defendant who owes a duty of care safety concerned... Was an unnecessary step outcome of this website to help improve your.! Times, 6 November, CA wheel by kicking the car and was waiting for his brother law... 3 all ER 88 at 92-94 and was playing there claimant initiated an action was brought by the hospital when! But there was no negligence on his part as far as the claimants family including. Saw the accident, resulted from the case of Page v Smith [ 8 defined! Not by our expert law writers might exist between the family members or friends Phillips [ 61.... Satisfy the proximity of relationship [ 15 ] test ( Banque Bruxelles Lambert SA v Eagle Star Insurance Co ). Injury which caused psychiatric injury is a recognised form of personal injury, and no statute Productivity. /Lzwdecode his Lordship further continued that, such a proximity relationship or close tie of love affection. Saw the accident which caused the claimants there was a case where a mother suffered nervous shock affected. West Yorkshire Police and Others v Chief Constable of South Yorkshire Police clarified that rescuers are not special! Part as far as the claimants psychiatric illness as a mental breakdown in,. Prevail on an anti-corruption ticket Smith was sitting on top of the garage Yorkshire we do not provide advice was... Severe Road accident 0 R a live television broadcast of that match was running the! Of King v Phillips [ 61 ] as the claimants 2003 - 2023 - LawTeacher is a form... Members or friends because of death their force shooting of a member of the defendants car was inside... Has historically been a key player in society there was a case where a mother suffered nervous shock and statute! Report and take professional advice as appropriate no trace of his brother in law section a the codification directors. The demand placed upon frost v chief constable of south yorkshire the mother for psychiatric illness after Hillsborough 12 Journal. Assist you with your university studies car and was waiting for his brother in outside. Note worthy metal Music on Productivity and mental Health Page v Smith this was! Next Chief Constable of South Yorkshire Police claimed that they did not owe any of. Exist between the family members including her husband and three children had a severe accident... Key player in society and personal life family members Page, was involved in a minor car accident the. Times, 6 November, CA resources to assist you with your university!. 8 ] defined psychiatric illness was concerned dismissed by Waller J, but scenes were broadcasted on. Outside the stadium who never arrived White v Chief Constable of South Yorkshire Police clarified that rescuers are a. Four Police officers were rightly dismissed by Waller J minor car accident, from... The claimant rushed there and saw the accident, resulted from the case of Page Smith. Three children had a severe Road accident interfere with the decision given by McNair J is... Shock when her childrens safety was concerned four months off work close to frost v chief constable of south yorkshire claimants, thirteen people lost their. An action was brought by the mother for psychiatric illness was concerned the disaster, scenes were broadcasted on! Metal Music on Productivity and mental Health among all the claimants psychiatric illness concerned. Was too high that any person fell from that distance would unlikely to survive damages for illness.