White v Chief Constable of South Yorkshire [1999] 2 A.C. 455

Police officers who worked during the Hillsborough disaster developed post-traumatic stress disorder after witnessing and assisting with its consequences. Their claims relied on the chief constable's responsibility for negligent crowd management. The officers argued that they could recover through the duty associated with their employment or through a special position as rescuers. They had not been exposed to physical danger, and the claims did not satisfy the ordinary close-relationship controls governing secondary victims. The House of Lords considered whether their professional role or rescue involvement nevertheless supplied a separate route to compensation.

Could officers avoid the secondary-victim controls by relying on their employment relationship or rescue work, although they were not physically endangered or reasonably believed to be so?

The House of Lords majority rejected the officers' claims. Their employment relationship did not itself give them a privileged route around the ordinary rules governing this kind of psychiatric injury. Nor did acting as rescuers automatically make them primary victims. They had not been physically endangered or reasonably believed themselves to be in such danger, and they did not satisfy the secondary-victim requirements. Some speeches favoured a broader approach, but that was not the majority outcome. The case does not mean employers never owe duties concerning psychiatric illness: occupational stress and other established contexts must be analysed separately. Its focus was psychiatric injury from witnessing the consequences of this disaster.

Employment or rescue involvement does not automatically remove the controls on psychiatric injury suffered from witnessing harm to others. The officers in White were not primary victims merely because they worked at the disaster, and their claims failed under the applicable secondary-victim requirements.

White must be read with Alcock, since both arose from Hillsborough but involved different claimants. The decision avoids treating a professional label as a substitute for the required relationship to danger or victims. Its restrictive result is not a rule denying all workplace psychiatric-injury claims. Paul later confirms the core secondary-victim framework while rejecting separate objective-horror and nervous-shock tests developed in some cases. Students should distinguish the majority's result from broader views expressed in individual speeches.