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It is an unfortunate truism that the topic of negligently-inflicted pure psychiatric illness is afflicted with many vagaries and complexities. That has been openly admitted, judicially. Recently, in RE v Calderdale and Huddersfield NHS Foundation Trust,2 the court described the law, in something of an understatement, as ‘not an area which is straightforward and without controversy’ – while, in Taylorson v Shieldness Produce Ltd, Ralph Gibson LJ remarked that the relevant principles are ‘as unconvincing as they are surprising’.
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