Insistence that psychiatric damage must be reasonably foreseeable, coupled with clear recognition that a plaintiff must prove psychiatric damage as I have defined it, and not merely grief, sorrow or emotional distress, will in my view enable the good sense of the judge to ensure, adopting Lord Wright's language in Bourhill v Young 1943 AC 92, 110, that the thing stops at the appropriate point.
This species of action is an action for restitution such as Lord Wright described in the Fibrosa case.
Radcliffe v Riddle Motor Services Ltd 1939 AC 215, 241, Lord Wright in a judgment restricting common employment notes ‘how little bargaining power a workman possessed’
"The truth is that the court .... decides this question in accordance with what seems to be just or reasonable in its eyes. The judge finds in himself the criterion of what is reasonable. The court is in this sense making a contract for the parties - though it is almost blasphemy to say so." (Lord Wright of Durley, Legal Essays and Addresses (1939), p259.)
Lewis Wright, Baron Wright of Ashton-under-Lyne (1903–1974), a British politician and trade unionist
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