... suffered severe shock and miscarried her baby. The Privy Council decided that there was no liability for psychiatric illness without a physical injury. The reasons given for this were the relative unknown working of the mind and the thought that any leaning towards favouring a claim as such may lead to a lot of falsified claims. However by the early twentieth century the courts were adopting a more liberal approach and this is seen in the case of Dulieu v White & Sons (1901) in which a pregnant barmaid, working behind the bar in a pub, suffered nervous shock when a runaway horse and carriage crashed through the front of the pub and stopped a short distance from where she was standing. She subsequently miscarried her child and this led to Kennedy J. upholding her claim, citing the case of Wilkinson v Downton, (1897). His Lordship did not hold with ...

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