White v Chief Constable of South Yorkshire Police
[1999] 2 AC 455
Ratio Decidendi
Police officers who attended the Hillsborough disaster as employees were not entitled to recover for psychiatric injury as rescuers unless they were in physical danger themselves. There is no special duty owed to rescuers for psychiatric harm where they are not exposed to personal danger.
Fakty
Police officers who attended the Hillsborough disaster suffered post-traumatic stress disorder. They claimed as employees (breach of employer's duty) or as rescuers. They had not been in personal physical danger.
Podsumowanie orzeczenia
The House of Lords held (by a 4-1 majority) that the officers could not recover. Rescuers were not a special category — they had to satisfy the normal rules for psychiatric injury claims. As they were not in personal physical danger, they were secondary victims and could not satisfy the Alcock control mechanisms.
Kluczowe cytaty
"To allow the claims of the police officers would be to allow them to recover where bereaved relatives could not. This would be unacceptable to the ordinary person."
— Lord Steyn
Późniejsze zastosowanie
Confirmed that rescuers must satisfy normal psychiatric injury rules. No special category of rescuer.