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Dulieu v White [1901]


  •  A carriage crashed into a pub, into the room in which a pregnant barmaid, the claimant, was working
  • The crush did not injure the barmaid, however she suffered mental injury and a subsequently gave birth to a child prematurely, who had developmental problems


  •  Was fear alone enough to create a mental injury claim?


  •  Yes, claim allowed


  • Recovery could be allowed if there was grounds for reasonable fear of immediate physical injury where there is no actual impact


[1901] 2 KB 669

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