“In delivering his opinion in Donoghue v Stevenson  AC 562;  All ER Reports 1, Lord Atkin used the neighbour principle as a metaphor to explain existing case law; it was not intended as a heuristic device for judicial expansion of the law of negligence. A legal neighbour is someone ‘so closely and directly affected’ that the defendant ‘ought to have them in reasonable contemplation as being so closely and directly affected’ ( AC 562 at 580). In modern parlance, the concept of proximity is used (Alcock v Chief Constable of the South Yorkshire Police  1 AC 310 at 397B;  4 All ER 907 at 913). This inquiry into proximity is especially pertinent in cases involving negligently inflicted psychiatric injury …”
Kumaralingam Amirthalingam, ‘Clinical negligence and relational psychiatric injury’ (2022) 138 Law Quarterly Review (July) 370-375.