Walker v Northumberland County Council [1995] 1 All ER 737

Facts

• Mr. Walker was employed as a social worker by Northumberland County Council, dealing with highly demanding cases.
• In 1986, Mr. Walker suffered a mental breakdown attributed to the sustained stress from his workload.
• After recovering and returning to work, Mr. Walker requested a reduction in workload or additional support, but the council took no substantive action.
• In 1987, he suffered a second, more severe mental breakdown, resulting in his dismissal.
• The claim alleged that the council failed to provide a safe system of work, leading to Mr. Walker’s psychiatric injury.

Issues

1. Whether an employer’s duty of care extends to the prevention of foreseeable psychiatric injury due to workplace stress.
2. Whether the council’s failure to adjust Mr. Walker’s workload after knowledge of his first breakdown constituted a breach of duty.
3. Whether policy or resource constraints excused the council from liability for workplace-induced psychiatric harm.

Decision

• The court held that the employer's duty of care extends to foreseeable psychiatric harm caused by workplace stress.
• It was determined that the first breakdown was not reasonably foreseeable, but the second breakdown was, due to the employer's knowledge of the previous incident.
• The council's failure to provide support or reduce Mr. Walker's workload after his return was found to be a breach of duty.
• The argument that resource constraints could shield the employer from liability was rejected.

Legal Principles

• An employer owes a duty of care to safeguard employees from both physical and psychiatric harm, where such harm is reasonably foreseeable.
• Foreseeability of psychiatric injury arises particularly after an employee suffers an initial breakdown, requiring employers to take reasonable steps to prevent recurrence.
• Courts maintain authority to assess the reasonableness of an employer’s response to known risks, regardless of resource constraints.
• The requirement of a safe system of work includes considering mental health risks linked to workload and job demands.

Conclusion

Walker v Northumberland County Council [1995] 1 All ER 737 marks a significant extension of employer liability to include foreseeable psychiatric harm arising from workplace stress, establishing that employers must take reasonable steps to protect employees’ mental health once a risk is known.