This case, which was decided by the House of Lords in April 2004, is extremely important in the context of claims for compensation for psychiatric injury.

 Mr Simmons worked as a burner for British Steel. In May 1996 he struck his head as a result of a tripping accident at work. He suffered from headaches and blurred vision which were not in themselves especially serious. However, his anger and frustration also caused him to develop a skin condition and a depressive illness at a later stage. The House of Lords agreed that he would be entitled to damages for both the skin condition and the mental illness, even though only the physical injury could have been foreseen.

 Courts may now be more inclined to recognise that an emotional reaction is a natural and foreseeable consequence of an accident and that a claimant should be able to recover damages if the reaction results in a psychiatric injury such as depression. British Steel plc v Simmons