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Alcock v Chief Constable of South Yorkshire Police [1991]


  • In the Hillsborough Football disaster, 95 people were killed and over 400 injured. The police authority admitted liability for all of the claims resulting from the estates of the dead and the injured
  • This case was a test case for all of the claims from people who saw but were not involved directly in the disaster, ie the non-injured. It involved people who were both at the stadium or informed of the event by others or by the media


  •  Under what circumstances could spectators of multiple descriptions recover



  • A primary victim is one who is a mediate or immediate participant in the incident
  • A secondary victim was one who is a passive bystander to the incident
  • All of the claimants in this case were classed as secondary victims
  • To succeed in a claim as a secondary victim, there must prove:
  1. A close relationship of love and affection with the injured
  2. Proximity to the incident in both time and space
  3. A means and suddenness of shock


[1991] 3 WLR 1057

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