What is the test for wilful infliction of mental distress?

A further requirement of the tort of wilful infliction of mental distress is that the defendant's conduct be "plainly calculated to produce some effect of the kind which was produced": Wilkinson v. Downton, supra, at p. 59. In the case at bar this element is established. It was clearly foreseeable that the accusations of theft which the defendant made against the plaintiff would cause her profound distress. That distress could only be exacerbated by the defendant's failure to conduct a proper investigation or allow the plaintiff to defend herself. It was equally foreseeable that the accusations would continue to cause distress into the future, when, in seeking employment, she would be queried by prospective employers as to the reasons for her dismissal from the defendant's employ.