In North Glamorgan NHS Trust v Walters [2002] EWCA Civ 1792 the claimant suffered psychiatric illness after negligent medical treatment led to the death of her 10 month-old baby. The Court of Appeal held that although the events leading to the claimant’s psychiatric condition took place over 36 hours, the series of events leading to the death could together constitute a ‘horrifying event’ , including witnessing the medical negligence. They also confirmed the trial judge’s ruling that the claimant’s appreciation of events was ‘sudden’ because each separate event had an immediate impact.