Pratt v. The Scottish Ministers [2011] ScotCS CSOH_86 (17 May 2011)

Pratt v. The Scottish Ministers [2011] ScotCS CSOH_86 (17 May 2011)

The SPS was not in breach of its duty of care; psychiatric injury was not reasonably foreseeable in the circumstances, and the pursuer received appropriate medical support. Referral to the Barlinnie Care Team would not have materially altered the outcome. The pursuer failed to prove causation between alleged breach and his depressive illness.

Citation
[2011] ScotCS CSOH_86
Parties
Pursuer: Edward Pratt; Defenders: The Scottish Ministers
Jurisdiction
Scotland
Judgment Date
17 May 2011
Procedural Posture
Personal Injury Action / Liability Proof; Damages Quantification Reserved
Outcome
Claim dismissed; no liability established
Legal Topics
Employer's Duty of Care, Psychiatric Injury, Negligence, Workplace Trauma, Counselling and Support Systems
Tort Employment Law Employer's Duty of Care Psychiatric Injury Negligence Workplace Trauma Counselling and Support Systems

Case Brief

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Parties

Edward Pratt

Pursuer

The Scottish Ministers

Defenders

Procedural Posture

Personal Injury Action / Liability Proof; Damages Quantification Reserved

Legal Issues

  1. 1 Did the Scottish Prison Service breach its duty of care by failing to provide early counselling and support to the pursuer after a traumatic workplace incident?
  2. 2 Was psychiatric injury to the pursuer foreseeable and preventable by the SPS?
  3. 3 Was the pursuer's depressive illness causally connected to the alleged breach?

Ratio Decidendi

The SPS was not in breach of its duty of care; psychiatric injury was not reasonably foreseeable in the circumstances, and the pursuer received appropriate medical support. Referral to the Barlinnie Care Team would not have materially altered the outcome. The pursuer failed to prove causation between alleged breach and his depressive illness.

Court Disposition

Claim dismissed; no liability established