Dalam kes Lee Nyan Hon & Brothers Sdn Bhd V Metro Charm Sdn Bhd [2009 ] 6 MLJ 1 di muka surat 22, perenggan 77 dan 78; telah memutuskan seperti berikut: “[77] The purpose of exemplary damages is to punish. And the quantum of the exemplary damages may be influenced by the size of the compensation sought even to the extent of exceeding the size of the compensation itself. In Rookes v Barnard And Others [1964] AC 1129, at p. 1228, Lord Devlin observed that: …a jury should be directed that if, but only if, the sum which they have in mind to award as compensation (which may, of course, be a sum aggravated by the way in which the defendant has behaved to the plaintiff) is inadequate to punish him for his outrageous conduct, to mark their disapproval of such conduct and to deter him from repeating it, then it can award some larger sum. [78] In Bradford City Metropolitan Council v Arora [1991] 2 QB 507, CA, the Court of Appeal while acknowledge that exemplary damages should be awarded only where compensatory damages are inadequate to punish the defendant, upheld an exemplary award of the industrial tribunal.”