A regular customer of the public house, named Mr Downton, decided to play a practical joke on Wilkinson's wife.

The effect of Downton's false statement to Mrs Wilkinson was a violent shock to her nervous system, causing her to vomit and for her hair to turn white and other more serious and permanent physical consequences which at one point threatened her reason, and entailing weeks of suffering and incapacity to her as well as expense to her husband for medical treatment.

That proposition without more appears to me to state a good cause of action...The reasoning in Wilkinson was upheld by the Court of Appeal of England and Wales in 1919 in Janvier v Sweeney.

[1] During the First World War, Mlle Janvier lived as a paid companion in a house in Mayfair, London, and corresponded with her German lover who was interned as an enemy alien on the Isle of Man.

The House of Lords later summarized the nature of the tort in Wainwright v Home Office, a case concerning a young man with cerebral palsy who had been strip-searched before visiting his brother in prison.

"[2] In 2015, the United Kingdom Supreme Court reviewed the jurisprudence surrounding Wilkinson, in the case Rhodes v OPO [2015] UKSC 32 and held that it could not be used to override the freedom to report the truth.