An education authority was found to owe a duty of care to motorists to protect against the risk of a young children in a public road; a driver was injured when forced to swerve, after a four-year-old child escaped and ran into the path of oncoming traffic. A duty of care will also apply to an omission if a dangerous act was committed by a third party on the defendant's property which he knew about or should have known about, and he did not take reasonable steps to avert damage to neighbouring properties. Special types of harm Psychiatric harm The duty of care owed to protect others from psychiatric harm is different from that owed for physical harm, with additional control devices and distinctions present in order to limit liability. A successful claim for psychiatric harm must result from a sudden shock (caused by a traumatising event), and the victim must be of ordinary fortitude and mental strength, and not especially susceptible to the harm in question. Whilst a prima facie duty of care is imposed for physical harm where the criteria of proximity, foreseeability, and policy are fulfilled, liability for psychiatric harm rests upon an individual's connection to a traumatising event; those not physically endangered may not be owed a duty of care unless they can fulfil several relational criteria. The decision of Page v Smith establishes liability for psychiatric harm where an individual is endangered physically. Victims in this category are known as primary victims, and are automatically owed a duty of care, as explained by Lord Lloyd: Further individuals are classed as secondary victims, and must meet several criteria in order to establish a duty of care is owed to them. There are several types of victims whom the court have recognised; employees who suffer excessive stress at work, individuals witnessing the destruction of their property, while those witnessing especially traumatising scenes involving others are secondary victims. Case law surrounding psychiatric harm focuses primarily on secondary victims; recovery for witnessing the injury and harm of others has been limited primarily by the decision of Alcock v Chief Constable of South Yorkshire, which establishes several boundaries and criteria for imposing liability. There must be a close tie of 'love and affection' between the primary victim, and the secondary victim witnessing the traumatic event. Additionally, the cause of the harm must be close and proximate to the shocking event