All claimants were unsuccessful because they did not fulfil the three main criteria for finding a duty to a ‘secondary victim’. These are a close relationship of love and affection to the victim, proximity to the event or its immediate aftermath, and direct personal perception of the event.

A pregnant fishwife suffered shock leading to a stillbirth when she heard a motorcycle accident and later saw blood on the road.

The defendant had owed no duty to the plaintiff in respect of her injury, which was unforeseeable as she was outside the range of danger. The law must expect a degree of fortitude from the public.

A member of the public assisted at the scene of a railway crash and sustained long-term psychological problems as a result.

The plaintiff’s claim for compensation was successful. At the time, this case appeared to indicate that the law would take a generous stance towards non-professional ‘rescuers’ in such circumstances.

A pregnant barmaid suffered shock when a horse and cart was driven through the window.

The plaintiff was awarded damages on the basis of her foreseeable fear for her own safety. This was the first successful English claim for psychiatric damage.

A mother died following shock she sustained having seen a runaway lorry heading for her children and hearing things which led her to believe that they had been hit.

Following the authority of Dulieu, it was held that liability could be extended to shock suffered due to fear for the safety of others. It may have been significant that this fear was for her children and that she experienced the event at first hand.

The plaintiff suffered shock following his exposure to an oil rig explosion and fire.

Because he was not in danger, he was not a primary victim and did not involve himself sufficiently in the rescue to qualify as a rescuer. His claim was unsuccessful.

A mother arrived at the hospital two hours after her family had been injured in a car accident and the shock of what she saw led to severe psychological illness.

The House of Lords unanimously ruled in her favour on the basis that although she had not witnessed the accident, she had seen the ‘immediate aftermath’.

The plaintiff was involved in a motor accident, due to the defendant’s negligence. He suffered a recurrence of chronic fatigue syndrome.

It was held that a duty was owed to him in respect of psychological injury. He was a primary victim due to the fact that he was in the range of possible physical injury, and therefore the Alcock criteria did not apply. Ultimately his claim failed, due to doubts about causation.

Police officers suffered shock following their involvement in the rescue and aftermath of the Hillsborough disaster, but their claim failed.

The House of Lords found that they were not primary victims, calling into doubt the decision in Chadwick. Because they did not fulfil the Alcock criteria for secondary victims, their claim failed.