Police officers investigating traffic accidents do not owe a duty of care to relatives of deceased victims in respect of the identification of bodies, because such a duty would be inconsistent with the officers' investigatory duties. The provisional nature of identification at an accident scene, where formal identification by relatives is expected to follow, means that psychiatric injury from misidentification is not reasonably foreseeable. Where relatives themselves incorrectly identify a body, this breaks the chain of causation from any earlier police error.
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