... where the claimant is under a duty to reduce their loss. Apart from the ordinary pecuniary loss suffered as a result of the breach, there are exceptions that non-pecuniary losses might be recoverable, but are generally not. This rule stems from the House of Lords authority of Addis v Gramophone Co. Ltd.i, where it was held that it was not possible to recover damages for the distress caused by the nature of a dismissal from employment as opposed to being directly caused by the breach itself. It follows that damages for distress are recoverable where it is directly consequent on physical inconvenience caused by the breach. In Heywood v Wellersii the plaintiff was entitled to damages for her distress and anxiety as they were a direct and foreseeable consequence of the solicitors' failure to obtain the relief which was the sole purpose of the contract. This principle was also applied ...

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