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#law #negligence #tort
The issue was again considered by the Court of Appeal in Cullin v London Fire & Civil Defence Authority [1999] PIQRP 314. Here the claimant was a fire fighter who suffered psychiatric injury after witnessing two colleagues trapped inside a burning building. His attempt at rescuing them had failed. Despite the defendant’s contention that this case mirrored White, the court disagreed, choosing instead to follow the obiter remarks of Lord Goff in that case. In Cullin it could be argued that the claimant, in his rescue attempt, was either exposed to the danger or reasonably believed he could be subjected to physical injury. As such he was a primary victim.
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