The reasoning followed was that he was in a danger zone and therefore it was foreseeable that he might suffer physical harm, i.e. that the destroyed carriage might fall on him. In the article 'The Page v Smith saga: A story of inauspicious origins and unintended consequences', it is said that Page's decision could have an expansive effect. This effect occurred in Young v Charles Church (Southern) Ltd (1998) 39 BMLR 146 where a successful claim for compensation for psychiatric harm suffered by witnessing the death of a work colleague was made. Since the appellant was also in the danger zone, he was treated as a primary victim. However, the definition of primary victim given in Page could also be treated as exhaustive and its effect could be restrictive, in the sense that inadvertent actors would not be able to make a claim because they would be treated as secondary victims (The Open University, 2016a ). The contradictory outcomes of cases that present very similar facts to the Court lead some jurists to call for reforms and to denounce the defects of the current common law rules. Some favor the implementation of a legal obligation to compensate for wrongfully caused mental harm
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