The Koehler v Cerebos test for foreseeability of psychiatric injury requires that psychological damage generally was reasonably foreseeable, not that the particular form of psychiatric injury suffered was foreseeable. Under s 23 of the Crown Proceedings Act 1958 (Vic), the Crown's vicarious liability requires proof of individual torts by servants or agents; the section does not by itself require aggregation of the conduct of multiple servants or agents. An employee's complaints about workload or industrial relations problems, without more, do not engage the employer's duty not to cause psychiatric injury.
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