Can a plaintiff recover damages for psychological disturbance caused to him by a motor vehicle accident?

Counsel for the defendant submitted that the plaintiff could not recover damages for any psychological disturbance caused to him by the accident, because it had not been proved that the psychological disturbance rose to the level of a recognized psychiatric illness, nor had it been proved that the psychological disturbance was causally connected to the minor physical injury sustained by the plaintiff. Counsel relied on Beaulieu v. Southerland (1986), 35 C.C.L.T. 237 (Legg J.). In that case, the plaintiff had not suffered any physical injury, but was walking with her friend along the road when her friend was struck and killed by the defendant’s motor vehicle. Mr. Justice Legg was satisfied that the plaintiff had suffered anxiety and grief and was extremely disturbed by the incident, but dismissed the action on the ground that she had failed to prove that her condition amounted to a recognized mental illness.