The sections below review tort claims made in an employment context. The field of torts is not closed. Innovation will lead to the development of new claims. Ironically, in Wallace one of the submissions made by the plaintiff before the Supreme Court was the creation of a new tort based on the duty of good faith. Apart from such a claim now being accepted in contract, as opposed to tort, the law has very much evolved to this concept.

The torts of first choice are the intentional infliction of emotional distress and in the case, of sexual wrongdoing, assault and battery.