A more recent example of a primary victim is the claimant in Page v Smith [1996] 1 AC 155. The claimant was involved in a car crash caused by the defendant’s negligence. While the claimant suffered no physical injury, the psychological effect of the car crash worsened his ME (Myalgic Encephalopathy) condition so as to render him permanently disabled. He was a primary victim because his condition arose from reasonable fear for his own physical safety.