The following PI & Clinical Negligence precedent Produced in partnership with Catriona Stirling of Cloisters Chambers provides comprehensive and up to date legal information covering:
IN THE COUNTY COURT AT [insert]
Claim No. [insert claim number]
[Mr A B] Claimant
[C D PLC] Defendant
Particulars of claim
At all material times, the Claimant was employed by the Defendant as a mail sorter at its Islington office and acting in the course of his employment. The Claimant’s employment commenced on [insert date]. At all material times, the Claimant’s line manager was [insert name of Claimant’s line manager, eg Mr Bloggs]. [Mr Bloggs]’ line manager was [insert name, eg Mr Jones]. The Defendant’s Managing Director was [insert name, eg, Mr Smith].
The Defendant owed the Claimant the following duties in tort and/or contract:
a duty to take reasonable care of the Claimant’s health and safety, which included employing competent fellow workers; and/or
a duty to take reasonable care to prevent the Claimant from suffering foreseeable psychiatric injury in the course of or as a result of his employment, which included protecting him from bullying and harassment at work.
The Defendant and its employees, including [Mr Bloggs], owed the Claimant a statutory duty pursuant to section 1(1) of the Protection from Harassment Act 1997 (PHA 1997) not to pursue a course of conduct which amounted to harassment of the Claimant.
At all material times, the Defendant was aware that the Claimant had a pre-existing psychiatric vulnerability, having received a letter from his General
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