Frost (or White) v Chief Constable of S Yorks Police [1999]

Plaintiffs were police officers who helped tend
victims of Hillsborough Stadium disaster.
Not in personal danger.
Claimed to have suffered mental injury.
Majority of Court of Appeal held some of them entitled
to succeed as rescuers – hence primary victims.
However House of Lords held that rescuer was not to be
placed in special position in relation to liability for psychological injury merely
because he was a rescuer.
Proximity requirement must be satisfied.
Proximity requirement in situation of psychological harm
suffered by rescuer was satisfied by showing actual or apprehended danger.

Police officers not entitled to recover.