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.

The answers, solutions, explanations, and written content provided on this page represent PastPaperHero's interpretation of academic material and potential responses to given questions. These are not guaranteed to be the only correct or definitive answers or explanations. Alternative valid responses, interpretations, or approaches may exist. If you believe any content is incorrect, outdated, or could be improved, please get in touch with us and we will review and make necessary amendments if we deem it appropriate. As per our terms and conditions, PastPaperHero shall not be held liable or responsible for any consequences arising. This includes, but is not limited to, incorrect answers in assignments, exams, or any form of testing administered by educational institutions or examination boards, as well as any misunderstandings or misapplications of concepts explained in our written content. Users are responsible for verifying that the methods, procedures, and explanations presented align with those taught in their respective educational settings and with current academic standards. While we strive to provide high-quality, accurate, and up-to-date content, PastPaperHero does not guarantee the completeness or accuracy of our written explanations, nor any specific outcomes in academic understanding or testing, whether formal or informal.
No resources available.

Job & Test Prep on a Budget

Compare PastPaperHero's subscription offering to the wider market

PastPaperHero
Monthly Plan
$10
Assessment Day
One-time Fee
$20-39
Job Test Prep
One-time Fee
$90-350

Note the above prices are approximate and based on prices listed on the respective websites as of May 2025. Prices may vary based on location, currency exchange rates, and other factors.

Get unlimited access to thousands of practice questions, flashcards, and detailed explanations. Save over 90% compared to one-time courses while maintaining the flexibility to learn at your own pace.

All-in-one Learning Platform

Everything you need to master your assessments and job tests in one place

  • Comprehensive Content

    Access thousands of fully explained questions and cases across multiple subjects

  • Visual Learning

    Understand complex concepts with intuitive diagrams and flowcharts

  • Focused Practice

    Prepare for assessments with targeted practice materials and expert guidance

  • Personalized Learning

    Track your progress and focus on areas where you need improvement

  • Affordable Access

    Get quality educational resources at a fraction of traditional costs

Tell Us What You Think

Help us improve our resources by sharing your experience

Pleased to share that I have successfully passed the SQE1 exam on 1st attempt. With SQE2 exempted, I’m now one step closer to getting enrolled as a Solicitor of England and Wales! Would like to thank my seniors, colleagues, mentors and friends for all the support during this grueling journey. This is one of the most difficult bar exams in the world to undertake, especially alongside a full time job! So happy to help out any aspirant who may be reading this message! I had prepared from the University of Law SQE Manuals and the AI powered MCQ bank from PastPaperHero.

Saptarshi Chatterjee

Saptarshi Chatterjee

Senior Associate at Trilegal