In Council of the City of Newcastle upon Tyne v Allan and others, Degnan and others v Redcar and Cleveland Borough Council, the EAT holds that there can be no claim for non-economic loss, that is for injury to feelings or for exemplary or aggravated damages, in claims under the Equal Pay Act 1970 because these are claims in contract rather than statutory torts, as in claims under the Sex Discrimination Act 1975.