in question, and it must be witnessed by the means of the victim's senses, and not via some form of communication. Pure economic loss Negligence which causes no physical or psychiatric harm, but causes economic loss to an individual or organisation, is termed pure economic loss. The idea that a duty of care may be owed to protect against the economic loss of others has been seen as problematic, as the bounds of such liability are potentially unforeseeable, and difficult to establish. Thus, there are several limits in place on the recovery of pure economic loss, with some categories of economic loss being totally unrecoverable altogether. Those affected by damage caused to the property of another company or individual, or who suffer loss due to the purchase of a defective product, for example, cannot ordinarily recover any losses incurred as a result. Instances where a duty of care is recognised generally involve the negligent performance of a service, or the negligent misstatements of professionals, which are then relied upon by others. The development of pure economic loss stems from the case of Hedley Byrne & Co Ltd v Heller & Partners Ltd, where it was first recognised that a duty of care may arise not to cause economic loss to others through negligent misstatements. In this case, Hedley Byrne, an advertising agency, approached Heller & Partners for a credit check on a third company, Easipower Ltd, before carrying out advertising orders on their behalf. Heller & Partners reported that Easipower Ltd was credit-worthy, and in reliance on this statement, Hedley Byrne placed advertising orders for them. When subsequently Easipower Ltd was declared bankrupt, Hedley Byrne took legal action against Heller & Partners, alleging they had been owed a duty of care when consulting for a credit reference. Whilst Hedley Byrne did not succeed in their claim, the House of Lords recognised that such a duty may be owed, where a relationship of reliance exists between two parties. Liability of public bodies An organisation or public body may be found to have committed a negligent act in the same way that an individual may; however, for policy reasons, the duty of care which a public body may owe is different from that of private individuals or organisations. Generally, it is where the type of harm involved is not of a physical kind, or a negligent omission is committed, that the formulation