An employer could be vicariously liable under the Protection from Harassment Act 1997 for harm caused by an employee harassing a colleague, including harm foreseeably and directly caused to another person; this could be a spouse living at the same address and caused alarm by the employee’s behaviour at that address. The Court of Appeal has ruled for the first time that an indirect victim of harassment may be able to claim damages under the 1997 Act. (Levi v Bates)