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Behrens & ors v Bertram Mills Circus Ltd. [1957] 2 QB 1

During a circus performance a dog antagonised the leading elephant, Bullu. Consequently some elephants stampeded into a side show where some dwarfs were performing.  Some of the dwarfs were injured and suffered shock.

Devlin J said:

"The real claim presented by Mr. Brown is for fright. An elephant coming over the top of a booth would be a terrifying thing even for an ordinary man, and although the male plaintiff asserts that he was not frightened, I am satisfied that the shock must have been considerable. I should like to award him a substantial sum under this head, but I am satisfied that I cannot do so except to the extremely limited extent that the shock resulted in physical or mental harm."

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