ABSTRACT
For the purposes of the 1974 Act, and regulations made thereunder, the chief constable is now deemed to be the employer of constables. This means that the chief constable is required to provide safe and healthy working conditions in more or less the same way as any other employer. Henry, LJ said that while the duty of care to the police officers was a factor in a case such as this where their employer had been negligent, he would expect a duty to be owed to them by any defendant who caused such a disaster. Where a plaintiff was a direct victim because of the duty that either his employer or the tortfeasor owed to him, that should be the first head of recovery to be considered, because it might be wider and would not be narrower than any entitlement as a rescuer.
