In claims for psychiatric injury, what is the difference between primary and secondary victims?

Question

What are the distinctions between primary and secondary victims of psychiatric illness?

Answer

A primary victim is a one who could have been in immediate physical danger, but only suffered psychiatric illness (White v CC of South Yorkshire [1999]). It is possible that even if the physical harm did not materialise, a defendant could still be liable to a victim of psychiatric harm (Page v Smith).

Secondary victims are those who were not in any danger of harm but rather become psychiatrically ill due to witnessing the death/injury of an immediate victim in which they have a loving and affectionate relationship with (Alcock v CC of South Yorkshire Police ([1992]).

It is important to note that the psychiatric injury must be a medically recognised condition. Thus, normal grief and distress would be insufficient.

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