Can a defendant be liable for causing nervous shock and physical injury to a plaintiff by falsely claiming that her husband had been injured in an accident?

The law has long recognized as tortious the uttering of false words or threats with the knowledge that they are likely to cause, and which actually cause, nervous shock and physical injury. One of the earliest cases to set out this duty was Wilkinson v. Downton, [1897] 2 Q.B. 57. In that case the defendant falsely represented to the plaintiff that her husband had been injured in an accident, inducing a state of nervous shock, vomiting and prolonged mental and physical suffering. Wright J. stated at pp. 58-59: The defendant has, as I assume for the moment, wilfully done an act calculated to cause physical harm to the plaintiff — that is to say, to infringe her legal right to personal safety, and has in fact thereby caused physical harm to her. That proposition without more appears to me to state a good cause of action, there being no justification alleged for the act. This wilful injuria is in law malicious, although no malicious purpose to cause the harm which was caused nor any motive of spite is imputed to the defendant.