Peter Handford's Note ("Psychiatric Injury: Duty to Employees' Children" (2003) 11 Tort L Rev 127) on the High Court decision in Gifford v Strang Patrick Stevedoring Pty Ltd (2003) 77 ALJR 1205; [2003] HCA 33 raises a number of important issues about the law in relation to recovery of compensation for psychiatric injury arising from workplace injury or death. This Note seeks to clarify two issues in areas where Handford suggests previous law is no longer operative.