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This statement is incorrect. In Haber v Walker [1963] VR 339 the court concluded that the dependant's action under the Victorian legislation is not limited by the remoteness of the harm.

Section 16 of the Wrongs Act 1958 (Vic) requires only that the deceased's death was caused by some act, neglect or default of the defendant. What needs to be established is a causal link between the defendant's act and the death, not that the death was a reasonably foreseeable consequence of the accident. There was a clear causal link in this case between the accident and Haber's death.

Note: Some more recent cases have cast doubt on the correctness of the decision in Haber v Walker.