Prison authorities owe a duty of care to employees of independent contractors working within a correctional centre to take reasonable care to protect them from psychiatric injury caused by the criminal conduct and threats of inmates. The duty arises from the special relationship characterised by the entrant's vulnerability, the authority's control over the prison environment and inmates, and the authority's assumption of responsibility for security. Following Tame v New South Wales, there is no requirement of sudden sensory perception or direct perception of a traumatic incident for recovery of damages for pure psychiatric injury, and no distinction between psychiatric injury and other personal injury cases in determining whether a duty of care exists.
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