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Frost v Chief Constable of South Yorkshire Police [1998]


  •  This case involved multiple police officers claiming they had suffered mental injury through rescuing the victims of the Hillsborough football disaster


  •  In which circumstances could secondary victims recover for mental injury


  •  None of the police officers recovered


  • See Alcock for secondary victim claim requirements
  • Did not fit primary victim classification – in no danger
  • Did not fit secondary victim classification – no relationship of ‘love and affection’ between the rescuers and the disaster victims
  • Employers have no duty to prevent employees seeing horrific sights in the course of their employment


[1998] WLR 1509

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