Damages for psychiatric injury are not recoverable for breach of an employment contract where the breach relates to the manner of termination. This applies both because such injury is too remote under Hadley v Baxendale principles (psychiatric injury not being within the reasonable contemplation of parties to an employment contract at the time of contracting as a not unlikely consequence of breach of due process provisions) and because the Addis principle, as confirmed in Baltic Shipping and subsequent authorities, precludes recovery for psychiatric injury (as distinct from physical injury) consequent upon wrongful termination. No duty of care in negligence is owed by an employer in respect of processes leading to termination of employment, consistently with Paige and subsequent appellate authorities across multiple jurisdictions.
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