Where a plaintiff suffers a single psychiatric illness caused by nervous shock that is subsequently aggravated by the foreseeable stress of caring for tortiously injured family members, the whole of the psychiatric injury is compensable, provided the chain of causation is not broken by a novus actus interveniens. The distinction in Jaensch v Coffey between shock-induced and non-shock-induced psychiatric illness does not require the concept of compensable damage to be artificially confined to the initial illness without regard for subsequent foreseeable aggravation. The claim for aggravation of the plaintiff's own psychiatric illness is conceptually distinct from any Griffiths v Kerkemeyer claim by the injured family member.
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